For Tax Professionals  

2006 IRS Actions on Decisions Library

All Actions on Decisions for 2006 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.

October 2006
Pacific Gas and Electric Company v. United States, 417 F.3d 1375 (Fed. Cir. 2005), rev'g 55 Fed. Cl. 271 (2003)
Issue: Whether the statute of limitations barred the Service from recovering erroneously paid overpayment interest by offsetting against a subsequent refund of tax and interest determined to be due to the taxpayer for the same taxable year.
October 2006
Erickson Post Acquisition, Inc. v. Commissioner Docket Number: 8218-00 T.C. Memo. 2003-218
Issue: Whether the cash payment from the wholesaler to the retailer was a taxable advance payment or a nontaxable loan.


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