( October 28, 2025, 8:19 AM EDT) -- KNOXVILLE, Tenn. — The Internal Revenue Service, in a cross-motion for summary judgment filed in a Tennessee federal court, argues that its disputed final rule governing small captive insurance arrangements was lawfully issued under its statutory authority, imposes only disclosure obligations and satisfies the Administrative Procedure Act’s (APA) requirement for a reasoned explanation, in response to a captive insurance manager’s challenge seeking to set aside the regulation as unlawful and in excess of the agency’s authority....