Research guides

Federal Taxation

Actions on Decisions & Acquiescences

Actions on Decisions (AOD) are formal memoranda prepared by the IRS Office of Chief Counsel that announce the future litigation position the IRS will take with regard to a specific court decision. The recommendation contained in an AOD becomes the notice of acquiescence.

Acquiescences and Nonacquiescences are statements issued by the IRS in response to the holdings in tax cases. The statement indicates whether the Service will or will not follow the holding. If they acquiesce, they accept the holding. If they acquiesce in result only, they accept the holding but raise concern about the reasoning. If they nonacquiesce, they disagree with the holding.

Notices of Acquiescence are published in the Internal Revenue Bulletin. Actions on Decisions are not. For where to find the Internal Revenue Bulletin, see the Internal Revenue Bulletin page of this guide.


Actions on Decisions Internal Revenue Service
Contains 1997 - present.

Onsite Lexis & Westlaw

IRS Administrative Decisions
Available on the library's Lexis computers. From the Content type tab, select Administrative & Agency Materials > Federal > Department of Treasury. A wide variety of materials, including, but not limited to, Decisions, Rulings, Orders, Memoranda, Interpretive Letters, Manuals, Bulletins, Circulars, Forms, News, and Speeches & Testimony from the IRS, Office of Comptroller & Currency, Alcohol & Tobacco Tax & Trade Bureau, Office of Thrift Supervision, Office of Foreign Assets Control, and the Financial Crimes Enforcement Network. Coverage varies by individual source.

IRS Actions on Decisions
Available on the library's Westlaw computers. From the All Content tab, select Administrative Decisions & Guidance > Internal Revenue Service IRS (listed under All Federal Administrative Decisions & Guidance) > Actions on Decisions. Contains 1967 - present with selected documents from 1935-1966.

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IRS Positions Reporter CCH
Library has 1982 - present. See Transfer Binders for 1982-2013.