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).