The First Circuit yesterday approved rulings by district courts coast to coast on the scope of Internal Revenue Service probes into potentially abusive tax shelters – in these cases involving write-offs of bad Brazilian debt.  The court held that the merits of the tax deductions don't matter so long as the IRS offers a "legitimate tax determination purpose".  Sugarloaf Funding LLC v. United States Dep't of Treasury, No. 08-2515 (1st Cir. Oct. 7, 2009).

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