The Department of Justice has cited my life insurance tax article with Ari Glogower in the appeal of this case in the Second Circuit. The case flips the usual sides on which party, the IRS or the taxpayer, wants to say who violated the investor control doctrine. https://www.bloomberglaw.com/product/blaw/document/X4O2P3ABI4O9NFBAM78JQK1HL54/download