2005 IRS Actions on Decisions Library

All Actions on Decisions for 2005 are only available in Adobe Acrobat PDF format. You will need the appropriate PDF Reader to view, print, or download the PDF version. There are different Acrobat Readers for different platforms. If you do not have the appropriate Acrobat Reader plugged into your browser, click on the link at the bottom of the page to obtain a FREE copy from Adobe. See the bottom of the page for links to AODs issued in other years.

AOD 2005-03(PDF)	December 2005
Montgomery v. Commissioner 122 T.C. 1 (2004)
Issue: Whether a taxpayer is barred from challenging the existence or amount of the underlying tax liability for a tax period in a collection due process (CDP) hearing under I.R.C. § 6330 solely because the tax liability was reported on the taxpayer’s tax return for that period.
AOD 2005-02(PDF)	September 2005
Sherwin-Williams Co. Employee Health Plan Trust v. Commissioner, 330 F.3rd 449 (6th Cir. 2003), rev'g 115 T.C. 440 (2000).
Issue: Whether the taxpayer’s investment income is excludible from its unrelated business taxable income under I.R.C. §512(a)(3) as exempt function income.
AOD 2005-01(PDF)	June 2005
Estate of Mitchell v. Commissioner, 250 F.3d 696 (9th Cir. 2001), aff'g in part, rev'g in part, and remanding T.C. Memo. 1997-461; on remand, T.C. Memo. 2002-98.
Issue: Whether the Court of Appeals erred in shifting the burden of proving the valuation of stock to the Commissioner on the basis that the Commissioner’s determination of the value of the stock was arbitrary and excessive.

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