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
1998-01 Beatty v. Commissioner, 106 T.C. 268 (1996). Reflects the Service's agreement that a county sheriff was entitled to reduce his gross receipts by costs of goods sold in computing income from providing meals to prisoners. 03/03/2000
2012-01 Baer Revoc.Trust v. U.S.,105 AFTR 2d 1544, 2 (D. Neb. 2010) Whether the stock includible in Decedent’s gross estate qualifies for the marital deduction under Sec. 2056(b)(7) when the stock is subject to contingent bequests. 04/09/2012
2001-02 Arnold W. Vinick v. USA, 205 F.3d 1 (1st Cir. 2000). Reflects the Service's nonacquiescence in the First Circuit's reversal of the lower court's decision that Vinick was liable as a responsible person under section 6672 for the unpaid withholding taxes of Jefferson Bronze Company. The First Circuit held that the lower courts' findings of fact were 'based on a misunderstanding of the legal standard for what constitutes a responsible person.' The court further stated that [a]bsent a 02/27/2001
2011-04 Appleton v. Comm., No. 10-4522 (3d Cir. June 10, 2011) Whether the 3rd Circuit erred in holding that the government of the U.S. Virgin Islands should be permitted to intervene in the Tax Court deficiency proceeding pursuant to Fed. R. Civ. P. 24(b)(2). 11/08/2011
2000-02 Ahadpour v. Comm., T.C. Memo. 1999-9. This Action on Decision reflects the Service's acquiescence in the Court's conclusion, to the extent, that the Tax Court held that petitioners had only a conditional right to retain the escrow payments. In the court's view, the unconditional right to retain the escrow payments arose only after buyer paid the remainder of the purchase price and the deed was delivered. 03/03/2000

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