Actions on Decisions (AOD)
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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 presents these documents in reverse chronological order, starting in the calendar year 1997.

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76 - 100 of 123 files Show per page:  25 50 100 200 « Previous | 1 2 3 4 5 | Next » 
Number Sorted Descending Help on Number Decision Not sorted Help on Decision Issue Not sorted Help on Issue Released Not sorted Help on Released
2000-09 Weisbart v. United States Dept of Treas. & IRS. Reflects the Service's acquiescence with the United States Court of Appeals for the Second Circuit's decision that section 7502 treats the claim as filed on the date of mailing (August 17, 1995) 11/17/2000
2000-08 John D. Shea v. Commissioner, 112 T.C. 183 (1999) The Tax Court held that the burden of proof should be placed on the Commissioner with respect to the section 66(b) issue. Rather than relying on established case law for its determination as to 11/03/2000
2000-07 Kathy A. King v. Commissoner, 115 T.C. No. 8 (Aug 10, 2000). Reflects the Service's acquiescence in the Court's conclusion that held that the nonpetitionering spouse was entitled to notice and an opportunity to intervene. The Tax Court reasoned that the rat 09/25/2000
2000-06 Diane Fernandez v. Commissioner, 114 T. C. No 21. Reflects the Service's acquiescence in the court's conclusion holding that when a taxpayer makes a requisite election under sections 6015(b) and/or (c) along with its request under section 6015(f), 09/25/2000
2000-05 Osteopathic Medical v. Commissioner, 113 T.C. No. 26. This Action on Decision reflects the Service's acquiescence in the court's conclusion that held that the taxpayer was not required to account for inventories or to use an accrual method of account 04/29/2000
2000-04 Smith v. Comm, 198 F.3d 515 (5th Cir. 1999), rev'g, 108 T.C. 412. The Tax Court upheld the Commissioner?s determination that the claim against the estate should be limited to the amount actually paid. The Tax Court held that, '[w]here a claim is disputed, conti 05/09/2000
2000-03 Simpson v. United States, 183 F.3d 812 (8th Cir. 1999). Reflects the Service's nonacquiescence in the Court's conclusion, that under the plain language of TRA 86 section 1433(b)(2)(A), the statutory protection applies to transfers under trusts that wer 03/04/2000
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 pa 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 prese 03/03/2000
1999-17 Duke Energy Natural Gas Corporation v. Comm. Reflects the Service's nonacquiescence in the court's conclusion holding that natural gas gathering systems are property includible in asset class 13.2 and must be depreciated over a 7-year period. 03/03/2000
1999-16 Conway v. Commissioner, 111 T.C. 350 (1998) Reflects the Service's acquiescence in the Court's conclusion that held that the transaction was a nontaxable exchange pursuant to section 1035. Consequently, the 10-percent penalty under section 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 juri 03/03/2000
1999-14 Mutual Assurance, Inc. v. United States, 56 F.3d 1353. Reflects the Service's nonacquiescence in the court's conclusion that held that a timely filed claim for refund that was allowed in full may be amended after the expiration of the statute of limi 03/03/2000
1999-13 Dubin v. Commissioner, 99 T.C. 325 (1992) . Reflects the Service's acquiescence in the court's conclusion that held although section 6231(a)(12) expressly provides that a husband and wife who have a joint interest in a partnership shall be 03/03/2000
1999-12 RJR Nabisco, Inc. et al. v. Commissioner, T.C. Memo. 1998-252. Reflects the Service's nonacquiescence in the Court's conclusion that held the graphic design and advertising campaign costs incurred by petitioner are currently deductible business expenses under 03/03/2000
1999-11 James J. and Sandra A. Gales v. Comm, T.C. Memo. 1999-27 Reflects the Service's acquiescence in the Court's conclusion that the advance commissions were loans rather than income in the year received., specifically finding that on occasion repayment was 03/03/2000
1999-10 Boyd Gaming Corporation v. Comm., 9th Cir. 1999. Reflects the Service's acquiescence in the Court's conclusion that held that the taxpayer's particular security and other business-related concerns provided sufficient justification for its polic 03/03/2000
1999-09 IRS v. Waldschmidt (In re Bradley), (M.D.Tenn. 1999). This Action on Decision reflects the Service's acquiescence in the Court's interpretation of amended setion 121 in light of section 1398 and declining to follow Mehr and Barden, held that a bankrup 03/03/2000
1999-08 Hospital Corp. of America and Subsidiaries v. Comm, 109 T.C. 21. Reflects the Service's acquiescence in the Court's conclusion, to the extent, that the Tax Court held that the term "tangible personal property," as defined under a pre-1981 ITC analysis, has con 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" nece 03/03/2000
1999-06 Estate of Mellinger v. Commissioner, 112 T.C. 4 (1999). Reflects the Service's acquiescence in the Court's conclusion that closely-held stock held in a QTIP trust should not be aggregated, for valuation pusposes, with stock in the same corporation held 03/03/2000
1999-05 St. Jude Medical, Inc. v Comm, 34 F. 3d 1394 (8th Cir. 1994). Reflects the conclusion by the Eighth Circuit that for purposes of calculating the CTI of a DISC, mandating the use of SIC categories to allocate R&D expenses is inconsistent with Congress's intent 03/03/2000
1999-04 Oshkosh Truck Corporation v. United States 123 F.3d 1477. Reflects the Service's acquiescence that a presumed markup percentage must be used in computing the vehicular excise tax on automotive articles sold to the United States directly by manufacturers 03/03/2000
1999-03 Murillo v. Commissioner, T.C. Memo. 1998-13. This Action on Decision reflects the Service's acquiescence in the Court's conclusion, in this case, that the Individual Retirement Account (IRA) forfeiture was similar to the Service's levy on a K 03/03/2000
1999-02 Larotonda v. Commissioner, AOD CC-1998-010. An action on decision stating that the Service will not acquiescence to the Court's conclusion in Larotonda. Recent legislation warrants the withdrawing of this AOD. The statutory provision effe 03/03/2000

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