The Supreme Court ศาลฏีกาof Virginia in Little v. Cooke determined ระบุthat certain damages were improperly awarded to a limited partnership in a derivative suit brought by plaintiff limited partners against defendants, a trustee, a professional corporation, and the general partner. The Supreme Court held that the limited partners’ derivative recovery was limited to damages suffered by the partnership and not the individual partners. The Supreme Court ruled that the partnership’s investors, not the partnership, incurred whatever income tax liability resulted from the sale of the apartment complex, the sole asset of the limited partnership. The Supreme Court held that the Circuit Court of Henrico County (Virginia) erred by awarding reasonable attorneys' fees and expenses in addition to the other damages awarded to the partnership. The supreme court ruled that, in accordance with the requirements of Va. Code Ann. § 50-73.65 Shepardize (2008), the award of attorneys' fees and expenses had to be paid from the "common fund" received by the limited partners on behalf of the partnership and the remainder remitted to the partnership.