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. View information about Using IRS Forms, Instructions, Publications and Other Item Files. Enter a term in the Find box. Click the Search button. 正在显示 126 - 130 of 130寻求帮助 发现 显示每一页 2550100200 搜索清除 编号 裁决 问题 发布日期 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 2000-01 McLeod v. United States, 276 F.Supp. 213 (S.D. Ala. 1967). Reflects the Service's acquiescence in the court's conclusion holding that the Department of Pensions and Security constructively placed the children in the taxpayer's home for adoption by presenting its favorable report to the court. Therefore, the requirements of section 152(b)(2) and Treas. Reg. § 1.152-(2)(c) were satisfied and taxpayer was entitled to the exemptions. In the Action on Decision in McLeod distributed on January 11, 1968, 1968 AOD LEXIS 75, the 03/03/2000 1999-07 Vulcan Materials Commpany and Subsidiaries v. Comm. Reflects the findings of the Tax Court that the statutory language of section 902(a) and its regulations are unclear. The Court was not persuaded that the reference to "accumulated profits" necessarily meant all of the foreign corporation's accumulated profits for the year. The Court interpreted the language "on or with respect to the accumulated profits of such 03/03/2000 1998-07 Clark D. & Janis L. Pulliam v. Comm., T.C. Memo. 1997-274. This Action on Decision reflects the Service's disagreement with the Tax Court's opinion, on the facts presented, that protecting against competition and retaining a key employee are valid corporate business purposes sufficiently compelling to overcome the evidence that a distribution of stock was used as a device for distributing earnings and profits. 03/03/2000 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 Pagination First page « 首页 Previous page 前一页 Page 1 Page 2 Page 3 Page 4 Page 5 当前页面 6