( September 16, 2026, 2:58 PM EDT) -- NEW ORLEANS — The owners of two microcaptive insurance arrangements ask the Fifth Circuit to overturn U.S. Tax Court rulings that disallowed deductions after finding that the arrangements did not constitute insurance for federal tax purposes and subsequently imposed penalties, arguing in part that the Tax Court improperly displaced state insurance regulation in violation of the McCarran-Ferguson Act, which bars federal interference with state insurance regulation without clear congressional authorization, particularly because the Tennessee Department of Commerce and Insurance (TDCI) had approved the reinsurance pool used by the captives as a risk-distribution arrangement....