( June 16, 2026, 2:35 PM EDT) -- CLEVELAND — The U.S. government urged an Ohio federal judge to deny summary judgment to a tax attorney and his captive entity in their refund suits challenging IRS promoter penalties assessed for alleged microcaptive tax shelter activities, arguing that the plaintiffs already have access to a de novo jury trial, that Congress may authorize administrative assessment of tax penalties under its taxing power and that tax penalty disputes fall within the public-rights doctrine....