( September 30, 2026, 12:49 PM EDT) -- PITTSBURGH — Ruling on what he called an issue of first impression concerning the constitutionality of the Internal Revenue Code’s (IRC) 15% prepayment requirement, a Pennsylvania federal judge denied renewed motions for dismissal and for summary judgment filed by a Pittsburgh-based corporation challenging more than $6.5 million in promoter penalties tied to a purported captive insurance program, applying in part a constitutional originalism analysis of the Seventh Amendment to determine that the requirement does not violate the right to a jury trial because it is analogous to founding-era requirements that parties whose assets are at risk post security before trial....