IRS Can't Probe Partner-Tier Employment Taxes, 1st Circ. Told

By Kat Lucero · January 20, 2026, 6:20 PM EST

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,...

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Case Information

Case Title

Denham Capital Management LP, et al v. Bessent

Case Number

25-1349

Court

Appellate - 1st Circuit

Nature of Suit

US tax court 

Date Filed

April 11, 2025