CIC Services to Appeal Denied Attorneys’ Fees in IRS Notice Bout

A micro-captive insurance adviser intends to appeal a lower court’s decision denying it attorney fees related to the company’s successful challenge of an IRS notice, according to a Tuesday filing with the US Court of Appeals for the Sixth Circuit.

According to the docket, CIC Services LLC plans to appeal a Sept. 11 decision from the US District Court for the Eastern District of Tennessee that said the company wasn’t entitled to attorneys’ fees because the IRS was “substantially justified” in issuing IRS Notice 2016-66.

• The US Supreme Court allowed CIC’s dispute on the notice to proceed in 2021, ...