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Considers Swift v. CIR, T.C. Memo. 2024-13 (Feb. 1, 2024), where a microcaptive was not deemed to be an insurance company and accuracy-related penalties were assessed. ....
Considers the opinion of the U.S. Tax Court in Keating v. CIR, T.C. Memo. 2024-2 (Jan. 4, 2024), where the IRS won a major victory in a microcaptive case. ....
Right? how unique is that? yeah. that is very unusual. you know, there have been some pretty quick turnarounds of people who got on a court of appeals and then found themselves having to figure out how to get to the supreme court to go to work after very little experience on the bench. you know, john roberts wasn t on the appeals court that long, amy coney barrett wasn t, so there could be some relatively quick turnarounds. that would be unusual. speaking of unusual, its unusual for a supreme court justice to hand deliver his letter of retirement, which is what we understand justice breyer did today. it s not unprecedented. we think justice kennedy did the same thing and so did harry blackmon, but usually when justices retire, they dispatch their letters down to the white house, so this is somewhat unusual but understandable in the current climate. i have to say i love his letter because it s so perfunctory. the first sentence cites the provision of 21 usc 31-b. ....