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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Showing 126 - 131 of 131
Find Help| Number | Decision | Issue | Release Date |
|---|---|---|---|
| Number 1997-06 | Decision Risman v. Commissioner, 100 T.C. 1991 (1993) (T.C. # 11429-91). | Issue 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. | Release Date 03/03/2000 |
| Number 1997-05 | Decision Hurt v. USA, 70 F.3d 1261 (4th Cir. 1995). | Issue 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. | Release Date 03/03/2000 |
| Number 1997-04 | Decision Duncan v. U.S., Docket No. 95-228 (U.S. D.C.,E.D. Ky.) | Issue 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. | Release Date 03/03/2000 |
| Number 1997-03 | Decision Buckeye Countrymark v. Comm., 103 T.C. 547 (1994) | Issue 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. | Release Date 03/03/2000 |
| Number 1997-02 | Decision United States v. Kao, 81 F.3d 114 (9th Cir. 1996). | Issue 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. | Release Date 03/03/2000 |
| Number 1997-01 | Decision Xerox Corporation v. United States, 41 F.3d 647 (Fed. Cir. 1994). | Issue 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). | Release Date 03/03/2000 |
