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IRS Actions on Decisions
FILE-NAME: AOD
COVERAGE: From October 1963 through current
FREQUENCY: Irregular; The Internal Revenue Service does not release this source often; LEXIS-NEXIS coverage is current.
UPDATE-SCHEDULE: Updated regularly - Atypical update schedule/as received from the agency
CONTENT-SUMMARY:
IRS Action on Decisions (AOD file) are documents issued by the Internal Revenue Service which discuss decisions rendered on a private or corporate taxpayer.
PUBLISHER:
Internal Revenue Service
SEGMENT-DESCRIP: | CITE | This segment contains the LEXIS citation used to describe this document. | | | cite (2007 AOD LEXIS 4) | | | | | DATE | This segment contains the date of release of the memo. | | | date=2007 | | | | | DISCLAIMER | This segment contains a disclaimer attached by the IRS. | | | disclaimer (precedent) | | | | | EXHIBITS | This segment contains the text of any exhibits provided with the memorandum. | | | exhibits (tax) | | | | | REFERENCE | This segment contains the author and department which is being copied on the memorandum. | | | reference (wdhussey) | | | | | TEXT | This segment contains the text of the memorandum. | | | text (stock options) | | | |
SAMPLE-SEARCH:
To find any actions on decisions discussing taking a deduction for home office
expenses, ENTER: home OR residence AND office w/25 deduct!
DOC-DESCRIPTION:
Each memorandum is a document.
DISPLAY-SEQUENCE:
Documents display in reverse chronological order.
USE-TIPS:
To find an Action on Decision which discusses IRS code section 183, ENTER:
I.R.C. section 183
HIER-LOC:
Area of Law - By Topic/Accounting/Access Directories/Tax Center/Federal/Primary/IRS
Area of Law - By Topic/Accounting/Find Statutes, Regulations & Administrative Materials/By Subtopic/Taxation/Find Federal Administrative Materials/Agency Decisions
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SAMPLE-DOC:
This document is not to be relied upon or otherwise cited as precedent by taxpayers.
Action on Decision 2007-05
AOD 2007-05; 2007 AOD LEXIS 4
October 18, 2007
[*1]
SUBJECT MATTER: Roosevelt Wallace v. Commissioner
Docket Number: 4637-03
128 T.C. No. 11 (April 16, 2007).
TEXT:
Issue:
Whether certain payments made by the Department of Veterans Affairs under the compensated work therapy program described in 38 U.S.C. 1718 are exempt from federal income tax as veterans' benefits.
Discussion:
In Wallace v. Comm'r, supra, 128 T.C. 132, the Tax Court held that payments made by the Department of Veterans Affairs from the Special Therapeutic and Rehabilitation Activities Fund described in 38 U.S.C. 1718(c)(1), for work performed under compensated work therapy programs, are exempt from federal income tax as veterans' benefits. In reaching its decision, the Tax Court rejected the Internal Revenue Service's (Service) published position, stated in Revenue Ruling 65-18, 1965-1 C.B. 32, that payments made under this program are includible in a recipient's gross income as compensation for services.
The Service will no longer litigate whether payments made by the Department of Veterans Affairs under the compensated work therapy program described in 38 U.S.C. 1718 are tax-exempt veterans' benefits.
Recommendation:
Acquiescence.
Reviewers:
Michael F. Schmit
Attorney
Approved:
DONALD L. KORB
Chief [*2] Counsel
George J. Blaine
Associate Chief Counsel
Income Tax & Accounting
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