Supreme Court Passes on $22.7 Million Distressed Debt Sale Case

The US Supreme Court denied review Monday of a partnership’s challenge to the IRS’s rejection of its $22.7 million tax deduction claim for a loss caused by the sale of distressed Brazilian receivables.

Pimlico LLC failed to convince the high court to grant its petition for a writ of certiorari, which asserted its deduction was both required and proper under the iteration of the Internal Revenue Code in operation at the time. The provision in question wasn’t overridden until after its claim, by the American Jobs Creation Act of 2004, the partnership’s petition alleged.

The US Court of Appeals ...