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Tax Court Again Considers an IRC Section 831(b) Case and Rules in Favor of the Internal Revenue Service

April 02, 2025

United States
United States
United States
Captive.com

In this Captive.com article, Eversheds Sutherland attorneys Saren Goldner and Bruce Wright review the Tax Court’s decision in Genie R. Jones, et al. v. Commissioner, T.C. Memo 2025–25, another case where a captive insurer electing under IRC §831(b) was found not to qualify as an insurance company for federal tax purposes.

The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer.

Key contacts

sarengoldner@eversheds-sutherland.com

Saren Goldner

Partner

New York, United States

brucewright@eversheds-sutherland.com

P. Bruce Wright

Of Counsel

New York, United States

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