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...
Captive Insurance
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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. The Avrahamis' first argument was that Feedback, their captive, hired qualified professionals to be sure it operated within the regulatory requirements therefore it...
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...