The plaintiffs in Drake Plastics Ltd. Co. v. Internal Revenue Service (IRS) have filed an appeal challenging the remaining portion of the court’s April ruling on IRS micro-captive regulations.
Following the decision earlier this month by the United States District Court for the Southern District of Texas, which struck down the IRS’s designation of certain 831(b) captives as “listed transactions,” the plaintiffs are now seeking to overturn the court’s finding that the IRS appropriately classified micro-captive arrangements as “transactions of interest”.
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