Case: Court of Appeals Upholds Dismissal of Taxpayer’s Suit Against IRS on Jurisdictional Grounds

The U.S. Court of Appeals for the Tenth Circuit affirmed the lower court’s decision dismissal of the taxpayer’s compliant for lack of jurisdiction. Taxpayer, a micro-captive insurance company, filed suit seeking declaratory and injunctive relief after the IRS determined it was not an eligible captive insurance company and issued notices of tax deficiency. The taxpayer challenged the IRS’s actions in federal court, claiming improper denial of eligibility as a captive insurer and wrongful obtainment of internal documents during an audit. The district court dismissed for lack of jurisdiction under the Declaratory Judgment Act (DJA) and Tax Anti-Injunction Act (AIA). The ...