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Tax Research

Use this guide as an introduction to researching federal tax questions, for tax policy research and for finding IRS documents and other tax-related materials.

Actions on Decisions / Acquiescence description

"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."   ( IRS Web site )

AODs indicate whether the IRS will follow a significant adverse opinion of the Tax Court, a district court, Court of Federal Claims, a bankruptcy court or an appellate court.  The recommendation, published in the Internal Revenue Bulletin, is characterized as an acquiescence, a nonacquiescence or an acquiescence in result only.   AODs are not intended to serve as public guidance and are not to be cited as precedent.     ( IRS Guidance 1980-2003,  Tax Notes, Nov. 15, 2004).

Sources for Actions on Decisions, Notices of Acquiescence, Nonacquiescence

Actions on Decisions abbreviations - AOD, action on dec.

Notices of Acquiescence abbreviations - acq or nonacq.