UPDATE – In its Action on Decision (AOD 2023-01, 2023-10 IRB 502), the Internal Revenue Service (“IRS”) announced its acquiescence to the holding of the Fifth Circuit in Trafigura Trading LLC v. United States, No. 21-20127, 29 F.4th 286 (5th Cir. 2022), i.e., that Internal Revenue Code (“IRC”) Section 4611(b)(1)(A) imposes a tax on…