Federal Court Dismisses APA Challenge to IRS ESOP Disqualification Action

On May 4, 2026, the US District Court for the Eastern District of Wisconsin issued its decision in Daines v. IRS, granting the Internal Revenue Service’s (“IRS”) motion to dismiss an action brought by Jeffrey and Elisha Daines, Jeffrey and Stephanie Federwitz, their related entities, and the Solid Ground Transportation, Inc. Employee Stock Ownership Plan (the “Solid Ground ESOP”).