IRS Actions on Decisions Library
An "Action on Decision" (AOD) is a document issued by the National Office litigation functions regarding whether the Service will follow a significant adverse court opinion. AODs may be issued with respect to a decision by the Tax Court, a U.S. District Court, the Court of Federal Claims, a Bankruptcy Court, or an Appellate Court. AODs are issued "to enhance Service consistency with respect to future litigation or dispute resolution." (See Internal Revenue Manual Section 18.104.22.168 for more information on AODs.). District Counsel, Appeals, Examination and other Service personnel may settle or pursue cases with the same controlling facts based upon an AOD's recommendation. Actions on Decision are not intended to serve as public guidance and are not to be cited as precedent. All AOD recommendations are published in the Internal Revenue Bulletin.
All Actions on Decisions are available in Adobe Acrobat PDF format and some are available in HTML format. You will need the appropriate PDF Reader to view, print, or download the PDF version. If you do not have the appropriate Acrobat Reader plugged into your browser, click on the HTML version if available, or click on the link at the bottom of the applicable index page to obtain a FREE copy from Adobe.
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