( March 9, 2026, 3:15 PM EDT) -- KNOXVILLE, Tenn. — A Tennessee federal judge denied a captive insurance manager’s motion for summary judgment challenging an IRS final rule governing a small captive insurance arrangement while granting the Internal Revenue Service’s cross-motion for summary judgment, holding that the final rule lawfully imposes disclosure requirements and is supported by a sufficient administrative record demonstrating concern about potential tax avoidance rather than improperly restricting statutory tax benefits....