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Avrahamis' Captive Manager Disputes Ruling

Multiple sources have reported that attorney Celia Clark, who formed the micro captive Feedback, for the Avrahamis, has commented on Judge Mark Holmes' decision to deny the motion for reconsideration. She claimed that the IRS has reviewed and approved very similar drafting templates to their administrative actions policy that the court criticized in its decision.

Some Suggest Avrahami Motion For Reconsideration drafted in a manner to help future malpractice litigation case against captive promoter

U.S. Tax Court, Judge Mark V. Holmes denied Avrahamis' motion of reconsideration on November 14, 2017.

US Tax Court denies Avrahami motion for reconsideration

The Avrahamis' motion for reconsideration was denied by Federal Judge Mark Holmes in November. The court concluded that at least one of the policies was so "ill-drafted" that it was both an occurrence policy and a claims-made policy. The Avrahamis argued, in the motion, that there should be no reasonable dispute that the policies were claims-made and not occurrence policies.

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