( March 19, 2025, 3:28 PM EDT) -- NEW ORLEANS — The Fifth Circuit U.S. Court of Appeals scheduled oral argument for April 1 in a case involving whether microcaptive insurance arrangements are ineligible for federal tax benefits and just over a week later granted an opposed motion for an out-of-time amicus brief by an individual facing IRS penalties who urges the court to adopt the U.S. Tax Court’s interpretation of the timeliness requirement for supervisory approval of penalties....