AOD (Action on Decision) is a document written by lawyers at the Internal Revenue Service to advise the Service’s Chief Counsel on how to proceed when a court decision is not in their favor. The document recommends whether the Service should agree with the decision, appeal it, or take alternative action.
An Action on Decision (AOD) is a legal memorandum prepared by attorneys in the litigation division of the Internal Revenue Service (IRS) for the IRS’s Chief Counsel. Its purpose is to provide guidance on whether the IRS should acquiesce, appeal, or pursue another course of action in response to an unfavorable court decision. For instance, if a court rules against the IRS in a tax case, the attorneys in the IRS’s litigation division will draft an AOD to recommend whether the IRS should appeal the decision or accept it and adjust their policies accordingly. In summary, an AOD is a tool used by the IRS to advise the Chief Counsel on the most appropriate action to be taken in light of a court ruling against the IRS, which may involve appealing the decision or modifying their policies to align with the court’s judgement.
An AOD is a legal memorandum issued by the IRS that explains the agency’s position on a particular tax issue.
An AOD is typically issued after the IRS has lost a case in court and has decided not to appeal the decision.
The purpose of an AOD is to provide guidance to IRS agents and taxpayers on how the agency will apply the court’s decision in future cases.
Yes, an AOD is binding on the IRS and its agents.
No, an AOD is not binding on taxpayers, but it can be used as persuasive authority in future cases.
Yes, an AOD can be challenged in court if a taxpayer believes that the IRS is not following the court’s decision.
The timing of an AOD can vary, but it typically takes several months after a court decision is issued.
Yes, an AOD can be withdrawn or modified if the IRS changes its position on a particular tax issue.
A taxpayer can search for AODs on the IRS website or contact the agency directly.
No, a taxpayer should not rely solely on an AOD as legal advice. It is important to consult with a qualified tax professional for guidance on specific tax issues.
This site contains general legal information but does not constitute professional legal advice for your particular situation. Persuing this glossary does not create an attorney-client or legal adviser relationship. If you have specific questions, please consult a qualified attorney licensed in your jurisdiction.
This glossary post was last updated: 17th April 2024.
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