Denham Capital Management LP, et al v. Bessent
Case Number:
25-1349
Court:
Nature of Suit:
Companies
Sectors & Industries:
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February 05, 2026
1st Circ. Probes Jurisdiction In Partner Employment Tax Case
First Circuit judges grappled Thursday with whether an energy investment fund's limited partners should be exempt from the self-employment tax, with much of the argument in the closely watched case focused on whether the U.S. Tax Court had the authority to make the decision in the first place.
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January 20, 2026
IRS Can't Probe Partner-Tier Employment Taxes, 1st Circ. Told
The IRS is not authorized to scrutinize a partner's taxable net earnings at the business-entity level under a 1982 law governing partnership audits, an energy investment firm told the First Circuit, challenging the agency's bid to subject limited partners to the self-employment tax.
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January 02, 2026
Top Federal Tax Cases To Watch In 2026
The application of self-employment taxes to limited partners, the economic substance doctrine's threshold and the question of whether IRS penalties need a jury's deliberation are topics federal courts likely will examine in coming decisions. Here, Law360 reviews the top federal tax cases to watch in the coming year.
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December 04, 2025
NYU Tax Group Backs IRS In 1st Circ. Limited Partner Row
Partners who are active participants in a partnership's business despite their status as limited partners under state law are not exempt from the self-employment tax, New York University's tax law center told the First Circuit in support of the federal government.
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November 26, 2025
Self-Employment Tax Applies To Partners, IRS Tells 1st Circ.
An energy investment fund's limited partners are not exempt from self-employment tax, the IRS told the First Circuit on Wednesday, saying the partnership wrongly relied on state law to treat full-time partners as passive investors and exclude them from the levy.