( June 26, 2026, 1:11 PM EDT) -- DALLAS — A tax firm told a Texas federal judge that a related Southern District of Texas ruling should not guide the court’s review of its Administrative Procedure Act (APA) challenge to the IRS’s final microcaptive insurance disclosure rule, arguing that although the ruling correctly vacated the rule’s listed-transaction designation, it failed to address defects in the rule’s loss-ratio thresholds, related-party financing criteria and factual support for the transaction-of-interest designation....