( October 29, 2026, 2:21 PM EDT) -- NEW ORLEANS — A tax consulting firm challenging the Internal Revenue Service’s final microcaptive insurance disclosure rule urged the Fifth Circuit U.S. Court of Appeals in an Oct. 28 appellant’s brief to reverse a Texas federal judge’s ruling upholding the rule’s transaction-of-interest designation, arguing that the agency failed to support its determination that microcaptive arrangements have a potential for tax avoidance with sufficient facts or data and exceeded its statutory authority under the Administrative Procedure Act (APA)....