IRS Grilled Over Self-Employment Tax Exemption Test on Appeal

Feb. 6, 2025, 5:33 PM UTC

A Fifth Circuit judge appeared highly skeptical of the IRS’s oral arguments on Thursday urging the panel to uphold a standard for when to disqualify state-law limited partners from a self-employment tax exemption.

Sirius Solutions appealed a US Tax Court ruling to increase its taxable net earnings from self-employment by $7.37 million for 2015 because the roles and activities of its state-law limited partners exceeded those of a passive investor. Supplanting the Tax Court’s passive-investor standard could offer significant tax benefits to businesses organized as limited partnerships.

Sirius argued the standard broke from past enforcement, but the IRS called its ...

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