Swift v. CIR
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January 30, 2025
New Penalty Rules Flawed, 5th Circ. Told In Microcaptive Row
Treasury's new rules on supervisory approval of penalties are flawed and don't apply to a couple's suit challenging tax penalties and denied deductions related to microcaptive insurance companies they operated for a network of urgent care clinics, an attorney for the couple told the Fifth Circuit.
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January 23, 2025
New Reg Hurts Taxpayer's Penalty Argument, US Tells 5th Cir.
Final regulations clarifying that an Internal Revenue Service supervisor can approve tax penalties at any time before the agency issues a deficiency notice undermines an appellant's arguments in a tax dispute, the U.S. government told the Fifth Circuit.
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December 19, 2024
5th Circ. Urged To Deny Tax Break For Doc's Captive Insurance
A physician who owns a network of urgent care clinics was correctly denied tax deductions along with his wife for over $1 million in premiums they paid to insurance companies they owned, the government told the Fifth Circuit, saying the captive arrangements didn't qualify as insurance for tax purposes.
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September 18, 2024
Tax Court Wrongly Denied Premium Deduction, 5th Circ. Told
A Texas couple asked the Fifth Circuit on Wednesday to reverse a U.S. Tax Court decision denying their bid to deduct more than $1 million in premiums paid to insurance companies they owned, arguing the Tax Court misclassified underlying insurance arrangements.