Legal Definitions - action on decision

Definition: Action on Decision (AOD) is a legal memorandum written by attorneys in the Internal Revenue Service's litigation division to the Service's Chief Counsel. It contains advice on whether the Service should acquiesce, appeal, or take some other action regarding a court's decision that is unfavorable to the Service.

Example: If a court rules against the IRS in a tax case, the attorneys in the IRS's litigation division will write an AOD to the Chief Counsel. The AOD will recommend whether the IRS should appeal the decision or accept it and change their policies accordingly.

Explanation: The example illustrates how an AOD is used in the context of a court ruling against the IRS. The attorneys in the IRS's litigation division will write an AOD to advise the Chief Counsel on the best course of action for the IRS to take. This could include appealing the decision or changing their policies to comply with the court's ruling.