Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues


Chart for the Tax Court Case of PICCIRC, LLC --- Disguised Sale & Partnership Shams

2024-04-23

Yesterday the Tax Court published its opinion for PICCIRC, LLC v. Commr., T.C. Memo. 2024-50. The court held that a contribution into a partnership was a disguised sale and that the partnerships were shams.

A chart of the case can be found here.

Tags: 701 Partnerships, Charts - Situational Charts