IRS Captive-Insurance Summons Is Abusive, Firm Tells 11th Circ.

Law360 (March 15, 2021, 4:29 PM EDT) -- An IRS summons seeking 11 years' worth of information on a law firm's captive insurance clients is abusive, the firm told the Eleventh Circuit on Monday, asking it to reverse a lower court's ruling requiring it to comply with the request.

A Georgia federal court erroneously enforced a summons issued by the Internal Revenue Service to Moore Ingram Johnson & Steele LLP, seeking years of documents on the firm's microcaptive legal practice, it said. The IRS request was far too broad and burdensome to comply with, the firm said in its brief.

The summons seeks information on the firm's captive insurance...

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