( July 28, 2025, 2:58 PM EDT) -- WASHINGTON, D.C. — Stating that “the Court failed to fully clarify two important issues” in a March opinion, a U.S. Tax Court judge issued a supplemental memorandum opinion in a consolidated case maintaining that a purported captive insurance arrangement could not exclude premiums from income during the 2015 and 2016 tax years because it is not considered insurance and that it must recognize $781,977 in income for the 2015 tax year because the provisions allowing deferral of unearned premiums do not apply to entities that are not insurance companies....