CIC Services, a micro-captive insurance adviser, is preparing to appeal a lower court decision that denied it attorneys’ fees. This fees are pertinent to the firm’s successful challenge of an IRS notice, claimed in a Tuesday filing with the US Court of Appeals for the Sixth Circuit.
The ruling CIC Services aims to appeal was delivered on September 11 by the US District Court for the Eastern District of Tennessee. The decision rendered that the insurance adviser was not qualified to receive attorneys’ fees since the issuance of the IRS Notice 2016-66 was “substantially justified”.
Footage of these legal proceedings can be found in a previous report.
A development to note, back in 2021, the US Supreme Court permitted CIC’s dispute regarding the notice to proceed, allowing an even broader judicial review of IRS’s strategies in future. This implies potential ramifications not just for CIC, but for attorneys in general. More on the Supreme Court’s decision can be tracked here.
The appeal of CIC Services is a significant ongoing issue within legal circles, and will undoubtedly keep practitioners on their toes considering its potential implications for future disputes involving the IRS and attorney’s fees.