CIC Services, LLC et al v. Internal Revenue Service et al
Case Number:
3:17-cv-00110
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March 09, 2022
Firm Calls For Ending IRS Microcaptive Disclosure Notice
An Internal Revenue Service notice requiring disclosure of microcaptive insurance arrangements under threat of penalty should be vacated, a microcaptive consulting firm told a Tennessee federal court, citing a Sixth Circuit decision regarding the agency's comment period obligations.
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February 11, 2022
4 Tax-Related Administrative Procedure Act Cases To Follow
A recent high-profile case in the Eleventh Circuit has once again demonstrated the power of the Administrative Procedure Act in challenges to IRS regulations alleging that the agency didn't follow the law in crafting regulations or other guidance. Here, Law360 looks at the Hewitt case and others that are primed to influence the extent to which the agency's compliance with administrative requirements may affect its ability to enforce its own guidance.
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January 03, 2022
Federal Tax Cases To Watch In 2022
In 2022, courts will mull whether a deadline for IRS collection challenges in federal tax law is a jurisdictional hurdle, weigh whether Treasury can disclose former President Donald Trump's tax returns and address a procedural challenge to microcaptive disclosure requirements. Here, Law360 looks at federal tax cases to watch in the new year.
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December 17, 2021
Microcaptive Co. Says It's Entitled To Discovery In IRS Fight
A magistrate judge wrongly denied an insurance advisory firm discovery to uncover the Internal Revenue Service's motivation for issuing guidance requiring the disclosure of microcaptive arrangements, the firm told a Tennessee federal court in its challenge to the reporting requirements.
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December 10, 2021
Microcaptive Co. Rightly Denied Expanded Discovery, US Says
A magistrate judge properly rejected an advisory firm's bid for expanded discovery in its dispute with the Internal Revenue Service over agency guidance requiring the disclosure of microcaptive insurance arrangements, the U.S. told a Tennessee federal court.
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November 30, 2021
Tenn. Court Urged To Block IRS Microcaptive Notice Nationally
A Tennessee federal court can issue a nationwide injunction against an IRS notice requiring the disclosure of microcaptive insurance arrangements under threat of penalty, and the only fair relief available is such a broad injunction, a microcaptive firm said.
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November 05, 2021
Court Won't Expand Discovery In Microcaptive Rule Case
A microcaptive insurance advisory firm cannot broaden discovery and gain additional time to show the Internal Revenue Service acted in bad faith by issuing industry-specific reporting requirements, a Tennessee federal court said Friday.
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November 02, 2021
IRS' Microcaptive Rules Didn't Break Admin Law, Court Told
The IRS told a Tennessee federal court it didn't violate administrative law by issuing a notice requiring the disclosure of microcaptive insurance arrangements under threat of penalty, rejecting arguments from a firm attempting to invalidate the guidance.
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October 15, 2021
IRS Seeks To Toss Microcaptive Firm's Request For Info
A Tennessee federal court should toss a microcaptive insurance advisory firm's moves to find out more about how a rule imposing penalties for not following industry-specific reporting requirements was created, the Internal Revenue Service said Friday.
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October 12, 2021
Microcaptive Advisory Firm Calls For Broader IRS Injunction
An injunction against the Internal Revenue Service from enforcing nondisclosure penalties against a microcaptive insurance advisory firm shouldn't be specific to the firm, but should instead enjoin enforcement altogether, the firm told a Tennessee federal court.
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