An Action on Decision (AOD) is a formal memorandum prepared by the IRS Office of Chief Counsel that announces the future litigation position the IRS will take with regard to the court decision addressed by the AOD.

The following list initially presents these documents in reverse chronological order, from the present back to calendar year 1997.

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Number Decision Issue Release Date
2011-05 William & Sharon Norris v. Comm., T.C. Memo. 2011-161 Whether the Tax Court erred when, in evaluating evidence of fraud, it weighed each of eleven badges of fraud equally, tallied the number “for,” “against” or “neutral,” and concluded that the Service did not establish fraud because only four of those badges had been proven. 12/09/2011
2012-07 Wilson v. Commissioner, 705 F.3d 980 (9th Cir. 2013), aff’g T.C. Memo. 2010-134 Whether I.R.C. § 6015(e)(1) provides both a de novo standard and a de novo scope of review in section 6015(f) cases petitioned to the Tax Court. 06/17/2013
1997-01 Xerox Corporation v. United States, 41 F.3d 647 (Fed. Cir. 1994). Reflects the Service's disagreement that the U.S.-U.K. Income Tax Treaty allows a United States corporation to treat advance tax paid by a U.K. subsidiary as a creditable tax under I.R.C. § 902(a). 03/03/2000
2010-03 Xilinx, Inc. v. Commissioner, 598 F.3d 1191 (9th Cir. 2010) Whether the Ninth Circuit Court of Appeals erred in concluding that under regulations promulgated under section 482 effective for taxable years 1997-1999, employee stockoption (ESO) compensation should not be shared in a qualified cost sharing arrangement (CSA). 07/16/2010
2017-05 Yosef A. Tsehay v. Commissioner, T.C. Memo. 2016-200 Nonacquiescence to the holding that a taxpayer whose filing status is married filing separately is entitled to an earned income tax credit. 07/06/2017
2012-06 Zapara v. Commissioner, 652 F.3d 1042 (9th Cir. 2011) Whether in a post-jeopardy levy Collection Due Process hearing, the Tax Court has the authority to order a credit to the taxpayer for the Service’s failure to comply with I.R.C. § 6335(f). 03/18/2013
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