Captive Manager Avoids 6700 Penalties After Jury Trial [Forbes]
The Goodyear Tire & Rubber Company (GT)
Last the goodyear tire & rubber company earnings: 4/30 07:15 am
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Source: Forbes
Back in 2016, when the IRS issued Notice 2016-66 that designated certain microcaptive insurance arrangements as "transactions of interest," I predicted that eventually there would be promoter examinations of at least some of the captive managers of captive insurance companies that had made the 831(b) election and were meeting risk distribution through risk pools, and that these promoter exams would result in the assessment of tax shelter penalties, a/k/a 6700 penalties (named after the Revenue Code section where those penalties are found). In 2021, I wrote about microcaptive promoter Celia Clark — who had featured prominently in several of the U.S. Tax Court opinions where the microcaptive owners had all lost and badly — being assessed such penalties and that she had filed a refund lawsuit, as related in my article, Former Microcaptive Promoter Sues IRS After Being Assessed With $11 Million In Section 6700 Penalties (Dec. 11, 2021). Ms. Clark and the IRS eventually settled that case
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GT
Earnings
- 2/12/24 - Beat
GT
Sec Filings
- 4/23/24 - Form 4
- 4/23/24 - Form 3
- 4/12/24 - Form 8-K
- GT's page on the SEC website