The IRS announced today that it plans to begin auditing several thousand more taxpayers that have operated section 831(b) or micro-captive insurance companies in the coming months. The IRS has been aggressively pursing taxpayers operating section 831(b) captives for several years, and it has been successful in its Tax Court litigation. The IRS's success in the courtroom has translated to success in audits as it essentially forces taxpayers to either concede or litigate with little opportunity for a resolution somewhere in between. As part of the announcement, the IRS publicized that nearly 80% of taxpayers offered its settlement initiative (a 90% taxpayer concession) have accepted it.