Rehearing Sought in Lawsuit Challenging Insurance Transaction

July 8, 2019, 5:13 PM

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 ...

To read the full article log in. To learn more about a subscription click here.