The US Internal Revenue Service has again rejected a claim for a $5.2m refund from the Limerick-based financier, JP McManus, that more than $17m he won gambling in the US in 2012 should be tax exempt on the basis he was not a tax resident in Ireland at the time.

McManus made the windfall playing backgammon over three days in California against the American private equity billionaire, Alec Gores.

He has argued that his winnings should be exempt from US income tax under the double taxation treaty between Ireland and the US, because he had paid the €200,000 domicile levy here in Ireland which covered all his overseas earnings.

The IRS in its latest ruling on the issue says Mr McManus’s "legal position bends the law beyond its breaking point."

US authorities have requested specific details about the games played, the businessman initially said that this information is "irrelevant."

The Irish Times reports that his lawyers told the IRS that Mr McManus, "does not remember the number of games or the amounts wagered per game."

"The wager was on the basis of points and the amounts to be wagered were altered during the competition at the request of the losing party," the legal team added.