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MANN CONSTRUCTION, INC. v. UNITED STATES

No. 21-1500.

27 F.4th 1138 (2022)

MANN CONSTRUCTION, INC.; Brook Wood; Kimberly Wood; Lee Coughlin; Debbie Coughlin, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: March 3, 2022.

Attorney(s) appearing for the Case

ARGUED: Samuel Joseph Lauricia III , WESTON HURD LLP, Cleveland, Ohio, for Appellants. Ellen Page DelSole , UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee. ON BRIEF: Samuel Joseph Lauricia III , Walter A. Lucas , Matthew C. Miller , Randy L. Taylor , WESTON HURD LLP, Cleveland, Ohio, for Appellants. Ellen Page DelSole , Francesca Ugolini , Geoffrey J. Klimas , UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee.

Before: SUTTON, Chief Judge; STRANCH and BUSH, Circuit Judges.

OPINION

Several taxpayers complain about the Internal Revenue Service's enforcement of an administrative regulation that requires them to report transactions involving cash-value life insurance policies connected to employee-benefit plans. The taxpayers claim that the IRS failed to meet a reporting requirement of its...

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