( May 5, 2026, 12:25 PM EDT) -- NEW ORLEANS — A plastics manufacturer, a captive insurer and a microcaptive manager on May 4 appealed to the Fifth Circuit U.S. Court of Appeals a Texas federal judge’s partial summary judgment ruling in their challenge to an IRS microcaptive disclosure rule, contesting the lower court’s determination that the agency acted within its statutory authority to require disclosure of potentially tax-avoidant transactions....