Rehearing Sought in Lawsuit Challenging Insurance Transaction

A Knoxville firm wants a rehearing from all the Sixth Circuit judges on a court opinion that affirmed the dismissal of a lawsuit challenging an IRS effort to crack down on micro-captive transactions.

CIC Services LLC was acting as an adviser to taxpayers participating in micro-captive transactions when the Internal Revenue Service issued Notice 2016-66, flagging the transactions as reportable for tax purposes. Failure to report such a transaction would trigger tax penalties.

The firm sued to stop enforcement efforts, arguing it violated the Administrative Procedure Act because taxpayers would have to pay ...