Christopher Rizek Talks to Tax Notes on Microcaptive Litigation

The IRS’s concession of the rest of the tax liability not conceded by the taxpayers left the court without anything to do despite petitioners’ wish for an opinion on the matter, according to the Tax Court.

Christopher S. Rizek of Caplin & Drysdale told Tax Notes that the IRS’s concession of the vast bulk of its asserted deficiency in the microcaptive insurance case Puglisi v. Commissioner is the first taxpayer victory on the issue he has heard of since the agency started focusing on the issue in the last five or six years. Rizek is one the petitioners’ attorneys.

. . .

“We wanted an opinion,” Rizek said. “But the net outcome is very taxpayer-favorable.”

For the full article, please visit Tax Notes’ website (subscription required).