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Second Circuit upholds IRS disallowance of $22.7 million loss from disguised partnership sale

Pimlico, LLC v. Commissioner, No. 24-1982, 2025 BL 281488, 2025 Us App Lexis 20239 (2d Cir. Aug. 11, 2025), Court Opinion

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Tax Coda
Oct 21, 2025
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The Second Circuit affirmed the Tax Court’s finding that Pimlico, LLC’s partnership transactions constituted a disguised sale, disallowing a $22.7 million tax loss claimed through a series of inter-entity transfers.

Holding

The court held that contributions and distributions among Pimlico, LLC, its affiliates, and a Brazilian company were properly treated…

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