( October 20, 2026, 10:22 AM EDT) -- PITTSBURGH — A Pittsburgh-based company challenging the IRS’s assessment and collection of tax shelter promoter penalties without a prior jury trial asked a Pennsylvania federal judge to certify for interlocutory appeal his order denying its renewed motions to dismiss and for summary judgment, arguing that the case presents novel constitutional questions about the agency’s penalty assessment framework, including a 15% prepayment requirement, that warrant immediate appellate review....