Tax Court Case Related Materials

On March 10, 2020, the owners of Puglisi Egg Farms of Delaware and its related captive insurance company filed petitions in the U.S. Tax Court to contest an IRS administrative determination concerning the tax treatment of its insurance structure. As of October 29, 2021, we are excited to announce that the U.S. Tax Court accepted the Internal Revenue Service’s concession of taxes and penalties initially proposed. Please see below for additional legal documents and articles in response to these events.

10.29.2021 Judge’s Order

10.29.2021 Oxford’s Response to the Judge’s Order

11.08.2021 Taxpayers Can’t Designate Their Microcaptive Case for Litigation

11.09.2021 IRS Drops Case in $2.7 Million Captive Insurance Clash

11.10.2021 Oxford Memo to Brokers

11.12.2021 IRS Granted Concessions in Tax Court Captive Dispute

11.21.21 – Subject – IRS Audits of Microcaptives – Gal Kaufman, Esq.