July 09, 2021
Over the next six months, courts may explore substantive administrative law challenges to microcaptive and conservation easement tax regulations, the future of an estate planning technique, the intersection of tax and insurance laws, and the scope of IRS summons powers. Here, Law360 looks at four federal tax cases worth monitoring in the second half of 2021.
August 29, 2019
The full Sixth Circuit will not rehear a company's challenge to Internal Revenue Service guidance that requires disclosure of potentially abusive microcaptive insurance arrangements.
May 22, 2019
A Sixth Circuit panel affirmed a court order Wednesday dismissing a challenge to Internal Revenue Service guidance that branded some small, in-house insurance companies as tax shelters and required them to be disclosed.
March 19, 2019
A policy statement issued by the U.S. Department of the Treasury on the regulatory process doesn't create any judicial rights, and the statement does not aid a captive insurance company challenging disclosure requirements, the government told the Sixth Circuit Tuesday.
October 19, 2018
The Internal Revenue Service's attorney defended the agency Friday before Sixth Circuit judges trying to understand why an insurer's lawsuit challenging a reporting requirement amounts to a banned attempt to restrain tax collection.
June 21, 2018
Insurer CIC Services LLC urged the Sixth Circuit on Thursday to reverse a lower court's dismissal of its suit, saying if the court agrees with the IRS' assertion that the case is barred by the Anti-Injunction Act, then that would strip courts the ability to make sure the agency doesn't usurp its legislative authority.
May 31, 2018
Requiring taxpayers to tell the Internal Revenue Service that they are using a questionable tax shelter — such as a captive insurance company — is related to tax collection and thus is protected by the Anti-Injunction Act, which bans lawsuits restraining tax collection activities, an IRS brief argued Thursday to the Sixth Circuit.
April 03, 2018
An insurance company that sued the Internal Revenue Service for unfairly labeling it as a tax scammer in a notice on captive insurance companies asked the Sixth Circuit on Monday to reverse a district court's dismissal of the case, claiming pre-enforcement review of an IRS notice is not barred by certain statutes.