( October 21, 2026, 2:34 PM EDT) -- CINCINNATI — The Sixth Circuit U.S. Court of Appeals issued a notice scheduling oral argument for Dec. 17 in a case in which a captive insurance manager asserts that a Tennessee federal judge erred in upholding an IRS final rule governing small captive insurance arrangements because the rule treats legitimate captives as abusive or potentially abusive tax-avoidance transactions without a sufficient abuse finding....