( May 22, 2025, 2:51 PM EDT) -- DALLAS — In response to the Internal Revenue Service’s motion to dismiss its challenge to a final rule requiring reports for certain microcaptive insurance arrangements, a tax consulting firm told a Texas federal court that it has standing because it is directly regulated and faces injury from the rule’s new reporting requirements; the tax firm further argues that dismissal is premature without review of the administrative record and that the issue should be resolved through summary judgment....