In CIC Services, LLC v. IRS,1 the U.S. District Court for the Eastern District of Tennessee invalidated Notice 2016-66 for failing to comply with the Administrative Procedure Act (APA). Notice 2016-66 prescribed disclosure requirements for taxpayers and material advisors involved in certain micro-captive transactions.
Court Invalidates IRS Notice 2016-66 on Micro-Captive Transactions, the Second Time an IRS Notice Was Vacated This Month
