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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Nimewo Desizyon Livrezon Dat Piblikasyon
1997-09 Royal Caribbean Cruises, Ltd. v. Commissioner, 108 F.3d 290. Reflects the Service's acceptance of the Eleventh Circuit's holding that the I.R.C. § 4471 excise tax on voyages on commercial passenger vessels does not apply to voyages on which passengers embark or disembark at intermediate stops within the United States if the voyage both begins and ends outside the United States. 03/03/2000
1997-06 Risman v. Commissioner, 100 T.C. 1991 (1993) (T.C. # 11429-91). AOD reflects the Service's continued disagreement with the factual finding that the taxpayer made a deposit, not a payment of tax, when the remitted a check with a request for extension of time for filing a return. 03/03/2000
1997-11 Trans City Life Insurance Company v. Commissioner. Reflects the Service's disagreement with the Tax Court's conclusion that the Commissioner abused his discretion in determining that reinsurance agreements entered into by the taxpayer with an unrelated insurer had a significant tax avoidance effect. 03/03/2000
1999-15 William & Helen Woodral v. Commissioner, 112 T.C.19 (1999). Reflects the Service's acquiescence in the Court's conclusion that it was unnecessary to look to the legislative history because the language of section 6404(g) clearly granted the Tax Court jurisdiction to review the Service's failure to abate interest under Section 6404, not just subsection 6404(e). The Court then concluded that the evidence failed to establish that the interest on the employment taxes was excessive in 03/03/2000
1997-07 The Edna Louise Dunn Trust v. Commissioner. Reflects the Service's agreement that a corporation's distribution of stock to shareholders in a spinoff of a subsidiary was tax-free under I.R.C. § 355(a)(1). 03/03/2000

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