Murfey v. WHC Ventures, LLC

Summary

The Court held that the limited partners had an independent contractual right to obtain copies of the partnerships’ Schedule K-1s for the proper purpose of valuing their partnership interests. Because the partnership agreements expressly included tax returns and specified partner information within the documents available for inspection, the Court declined to imply a separate “necessary and essential” limitation or to treat the K-1s as excluded investor information. The Court reversed and remanded, permitting access subject to redaction of identifying numbers and continued confidential treatment.