( April 8, 2026, 8:00 AM EDT) -- PITTSBURGH — The U.S. government urged a Pennsylvania federal court to reject a Pittsburgh-based corporation’s renewed bid for summary judgment and dismissal of the government’s counterclaim seeking to enforce more than $6.5 million in promoter penalties tied to the company’s administration of a purported captive insurance program, arguing that the motions are procedurally barred and that binding precedent forecloses the corporation’s Seventh Amendment challenge to the Internal Revenue Code’s prepayment and administrative assessment structure....