A partnership is asking the US Supreme Court to overturn a ruling that the IRS correctly disallowed a claimed deduction based on a $22.7 million loss from its sale of distressed Brazilian receivables.
The loss deduction, which flowed through to PIMLICO LLC from a related partnership, was an improper disguised sale aimed at generating tax benefits, the IRS said.
The US Court of Appeals for the Second Circuit held in August 2025 that the US Tax Court correctly observed that the transaction “had the effect of engineering a tax windfall” for some of the investors in Brazilian metal products supplier ...