( November 24, 2025, 8:47 AM EST) -- PITTSBURGH — A Pittsburgh-based corporation asks a Pennsylvania federal court to reconsider the denial of its motion to dismiss and for summary judgment in a dispute over penalties tied to the corporation’s alleged promotion of a tax shelter through a purported captive insurance program, arguing that the judge misapprehended its filings and failed to address its claim that requiring prepayment of part of the IRS promoter penalty before a jury trial violates the Seventh Amendment....