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.