February 06, 2026
A partnership asked the U.S. Supreme Court to revive its $23 million loss deduction involving a Brazilian company, saying in a petition docketed Friday that the Second Circuit wrongly blocked a key argument and that an IRS anti-abuse regulation applied against the partnership should be invalidated.
August 11, 2025
The U.S. Tax Court correctly found the IRS properly denied a Connecticut partnership's $22.7 million loss deduction because the underlying transactions, which involved a Brazilian company, were tantamount to a disguised property sale, the Second Circuit ruled Monday.