The Internal Revenue Service is asking for $2.7 million in taxes from race driver Juan Pablo Montoya, and he has filed a lawsuit in the U.S. Tax Court challenging the IRS’s assessment.

The tax dispute centers around the use of an offshore corporation in the Bahamas to which the Colombian race car driver assigned the rights to his “driver identity”—including his image, name, appearance and voice—before moving to the U.S. in 2007, according to Forbes.

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