"The court reasoned that administration of the Code rests with the IRS absent an express delegation of authority to another agency, and that no such express delegation existed here.... Concluding that Letter 226-J satisfied the certification requirement, the court ruled without a trial in favor of the government and denied the employer's refund claim.... This decision creates a split at the trial court level on the question of whether the IRS or HHS has the authority to issue the certification required before an employer shared responsibility penalty can be assessed." [Supreme Linen Services, Inc., v. U.S., No. 25-20723 (S.D. Fla. Feb. 25, 2026; on appeal to 11th Cir. No. 26-11299)]  MORE >>