HDH GROUP, INC v. UNITED STATES OF AMERICA
Case Number:
2:24-cv-00988
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Firms
Government Agencies
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February 10, 2026
Broker Renews Fight Against $6.6M Civil Fraud Penalties
An insurance broker renewed challenges to a $6.6 million civil fraud tax penalty over its captive deductions by arguing that the assessment required a jury trial, telling a Pennsylvania federal court that recent rulings, including in the Fifth Circuit, have reinvigorated requests the court previously denied.
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December 23, 2025
Top Federal Tax Decisions Of 2025
Over the past year, federal courts have issued decisions that extended the deadline for challenging tax bills in the U.S. Tax Court, allowed the IRS to pursue a woman's decades-old tax debt caused by her return preparer and lifted a $1 million reporting penalty because a jury didn't sign off. Here, Law360 reviews some of the most significant federal tax decisions of 2025.
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September 23, 2025
$6.6M IRS Civil Fraud Penalty Ruled Constitutional
A Pennsylvania federal judge upheld a $6.6 million civil fraud tax penalty against an insurance broker over its captive deductions, ruling Tuesday that the Internal Revenue Service's assessment of the penalty without a jury trial was constitutional.
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July 03, 2025
Top Federal Tax Cases To Watch In 2nd Half Of 2025
In the second half of this year, tax professionals will be keeping an eye on suits challenging the IRS' handling of employee retention tax credits and litigation over new microcaptive insurance regulations, as well as disputes over civil fraud penalties. Here, Law360 looks at the top federal tax cases to monitor during the rest of 2025.
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June 03, 2025
Precedent Does Apply To $6.6M Microcaptive Case, Court Told
A captive insurance program operator challenging $6.6 million in tax fraud penalties told a Pennsylvania federal court that the government boldly and incorrectly claimed that the U.S. Supreme Court's landmark ruling requiring a jury to make certain fraud findings doesn't apply to its case.
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April 25, 2025
US Seeks To Block Refund For Captive Insurance Penalties
A Pennsylvania federal court should reject a company's bid for an immediate penalty refund for operating what the IRS claimed is an abusive tax shelter through its microcaptive insurance program, the government argued Friday, saying the company is seeking protection in an unrelated U.S. Supreme Court ruling.