Despite the latest 831(b) micro-captive case, CFM Insurance, Inc. v. Commissioner of Internal Revenue, once again going in favour of the Internal Revenue Service, this particular case proved a much closer affair, with the Tax Court ruling in favour of the captive on certain issues, particularly around risk distribution.
Robertino and Antonella Presta own a local chain of grocery stores in the Chicago area, operating under the “Caputo’s” brand.
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