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2004 IRS Actions on Decisions Library

All Actions on Decisions for 2004 are only available in Adobe Acrobat PDF format. You will need the appropriate PDF Reader to view, print, or download the PDF version. There are different Acrobat Readers for different platforms. If you do not have the appropriate Acrobat Reader plugged into your browser, click on the link at the bottom of the page to obtain a FREE copy from Adobe. See the bottom of the page for links to AODs issued in other years.

United States Internal Revenue Service v. Donald Snyder
Issue: Whether the value of a debtor�s interest in a pension plan that is excluded from the bankruptcy estate under Bankruptcy Code � 541(c)(2) should be included in the value of the Service�s secured claim under Bankruptcy Code � 506(a).
Diane Fernandez v. Commissioner
Issue: Whether the Tax Court has jurisdiction, under I.R.C. � 6015(e) in a case involving an understatement of tax, to review the Service's determination to deny relief under section 6015(f).
Kaffenberger v. United States
Issues 1. Whether the Form 4868, Application for Automatic Extension of Time to File U.S. Individual Income Tax Return, constitutes an informal claim for refund. 2. Whether the 2-year period of limitations, set forth in I.R.C. � 6532(a)(1), for bringing a refund suit can be extended once the 2-year period has expired.
United States v. Roland Harry Macher (In re Macher)
Issue: Whether a bankruptcy court has the authority to order the United States to process and consider a debtor�s plan of reorganization in accordance with procedures applicable to offers in compromise submitted by taxpayers who are not currently in bankruptcy.
Tax Analysts v. Internal Revenue Service
Issue: Whether letter rulings issued by the Service that deny or revoke an organization�s tax exempt status are subject to public inspection under I.R.C. � 6110.
Sidney L. Olson and Miriam K. Olson v. Commissioner
Issue: Whether the distribution of the stock of a controlled corporation by a distributing corporation to the shareholders of the distributing corporation to prevent the potential union of the distributing corporation from claiming that the distributing and controlled corporations constitute a single employer for labor law purposes qualifies as a valid corporate business purpose under � 1.355-2(b) of the Income Tax Regulations. 0355.04-00, 0316.00-00, 0301.01-00, 301.02-00


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