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Managing Partner, Anthony Daddino was quoted in a March 13, 2023 Tax Note article written by Kristen A. Parillo

Managing Partner, Anthony Daddino was quoted in a recent Tax Notes article written by Kristen Parillo on March 13, 2023 titled, "Limited Partner Status Requires Functional Analysis, IRS Says."  State law limited partners aren't automatically entitled to the statutory exemption from self-employent tax, the IRS contends in a Tax Court case brought by a New York hedge fund, in Soroban Capital Partners LP v. Commissioner.

In the article section titled, "So Many Questions",  Mr. Daddino comments that the IRS's argument that the term limited partner is ambiguous raises more questions than it answers. He further states that the Tax Court will have to wrestle with the question of "what is ambiguity?" in answering the threshold issue.  The court said in Renkemey that the meaning of limited partner has become obscured.  But Daddino then asked the question, "does that render the statutory term limited partner ambiguous on a de factor basis?"