Tax Court Briefing On Economic Substance Doctrine Continues In Microcaptive Case

( December 24, 2024, 9:29 AM EST) -- WASHINGTON, D.C. — In their latest filings in a U.S. Tax Court dispute over the “economic substance doctrine” in consolidated cases involving purported microcaptive insurance companies, the commissioner of Internal Revenue argues that a “threshold” determination of relevance is not required and the petitioners contend that the bulk of the amicus curiae briefs support their contrary position, among other things....

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