Tom Jones Finds Taxpayer-Positive Interpretation of “Avrahami” Decision


Thomas Jones said the US Tax Court’s Avrahami decision, while negative for some insurance captives, also provides further clarity and should be beneficial to larger captives. “The IRS chose to litigate this case because it thought it would win,” Mr. Jones noted. “On the taxpayer risk continuum, the facts and circumstance in this case taken together are a dark shade of gray.”