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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Número Decisión Problema Fecha de publicación
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
2012-08 Media Space, Inc. v. Commissioner, 135 T. C. 424 (2010), vacated, 477 Fed. Appx. 857 (2nd Cir. 2012) Whether the taxpayer’s forbearance payments to its preferred shareholders were (1) ordinary and necessary business expenses that were not required to be capitalized under section 263(a), (2) not nondeductible distributions to the shareholders under section 301, and (3) not pursuant to a reacquisition or an exchange of stock to which section 162(k) or section 361(c)(1) applied. 08/05/2013
2019-03 GreenTeam Materials Recovery Facility PN, GreenWaste Recovery, Inc., Tax Matters Partner, et al. v. Commissioner Whether the transfer of a non-capital asset is treated under § 1253 as the sale or exchange of a capital asset if the transferor does not retain any significant power, right, or continuing interest. 10/15/2019
2010-05 VERITAS Software Corp. v. Commissioner, 133 T.C. No. 14 Whether the U.S. Tax Court erred in concluding that the comparable uncontrolled transaction (CUT) method, with adjustments, was the best method to determine an arm’s length result. 11/10/2010
2004-06 IRS v. Donald Snyder, 343 F.3d 1171 (9th Cir. 2003). Whether the value of a debtor's interest in a pension plan that is excluded from the bankruptcy estate under Bankruptcy Code Section 541(c)(2) should be included in the value of the Service's secured claim under Bankruptcy Code Section 506(a). RELEASE DATE: 10/18/2004. 10/18/2004

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