( June 25, 2026, 12:23 PM EDT) -- NEW ORLEANS — The IRS, the Department of the Treasury and their respective heads have cross-appealed to the Fifth Circuit U.S. Court of Appeals a Texas federal judge’s final judgment vacating the agency’s designation of certain microcaptive arrangements as listed transactions, after a plastics manufacturer, its captive insurer and a microcaptive manager appealed the same mixed ruling insofar as it upheld the IRS’s authority to require disclosure of the arrangements as transactions of interest....