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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Number Decision Issue Release Date
1997-05 Hurt v. USA, 70 F.3d 1261 (4th Cir. 1995). Reflects the Service's disagreement with the Fourth Circuit's opinion that the Service was not entitled to collect statutory interest on the taxes assessed pursuant to a Tax Court decision based upon a settlement agreement. 03/03/2000
1997-04 Duncan v. U.S., Docket No. 95-228 (U.S. D.C.,E.D. Ky.) Reflects the Service's agreement that disability benefits paid from a Kentucky policemen and firefighter's retirement fund can be excluded from gross income under I.R.C. § 104(a)(1) as benefits paid under a statute in the nature of a workmen's compensation act. 03/03/2000
1997-03 Buckeye Countrymark v. Comm., 103 T.C. 547 (1994) Reflects the Service's agreement that nonexempt cooperatives subject to subchapter T of the Internal Revenue Code are permitted to carry back losses from furnishing goods and services to its members to earlier tax years under I.R.C. § 172. 03/03/2000
1997-02 United States v. Kao, 81 F.3d 114 (9th Cir. 1996). Reflects the Service's acquiescence in the result that the Service could not, by issuing summonses, compel taxpayers to sign consent directives authorizing the release of records from unidentified domestic and foreign banks. 03/03/2000
1997-01 Xerox Corporation v. United States, 41 F.3d 647 (Fed. Cir. 1994). Reflects the Service's disagreement that the U.S.-U.K. Income Tax Treaty allows a United States corporation to treat advance tax paid by a U.K. subsidiary as a creditable tax under I.R.C. § 902(a). 03/03/2000
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