( November 11, 2026, 12:27 PM EST) -- PITTSBURGH — The U.S. government in a Pennsylvania federal court opposed a Pittsburgh-based company’s motion to certify for interlocutory appeal a federal judge’s ruling that the assessment of tax shelter promoter penalties and a 15% prepayment requirement do not violate the Seventh Amendment’s right to a jury trial, arguing that an immediate appeal would only delay resolution of the company’s suit seeking a refund of penalties tied to a purported captive insurance program....