On 15 April 2026, the US District Court for the Southern District of Texas issued its opinion in Drake Plastics v IRS. It upheld the micro-captive transactions-of-interest regulation, 26 CFR 1.6011-11, but declared the listed-transaction regulation, 26 CFR 1.6011-10, unlawful and vacated it. The court stayed that vacatur until 1 May 2026. The court found the administrative record insufficient to support the listed-transaction designation under the applicable standard. Its