Summary Judgment Bid, Dismissal Of Counterclaim Denied In IRS Penalty Case

( September 25, 2025, 1:10 PM EDT) -- PITTSBURGH — A Pennsylvania federal judge denied a corporation’s motion to dismiss a counterclaim filed by the U.S. government and motion for summary judgment in a dispute over the alleged promotion of a tax shelter through a captive insurance arrangement, ruling that while the IRS penalties at issue implicate the Seventh Amendment, the statutory scheme is constitutional because the corporation may seek de novo jury trial review in federal court....