( September 17, 2026, 9:05 AM EDT) -- CINCINNATI — The Internal Revenue Service seeks affirmance in the Sixth Circuit U.S. Court of Appeals of a lower court’s ruling that upheld a disputed agency final rule that established two regulations governing small captive insurance arrangements, maintaining that it acted within its congressionally delegated authority to promulgate the directive and that its implementation does not violate the Administrative Procedure Act (APA)....