Schell v. United States

MEMORANDUM OPINION AND FINAL ORDER

BRADEN, Judge.

I. FACTUAL BACKGROUND.1

In the mid-1980s, William H. Schell invested in two limited partnerships offered by American Agri-Corp (“AMCOR”)2. William H. Schell held a limited partnership interest in Canyon Desert Vineyards (“CDV”) during the tax years 1985-93 and in Vista Ag-Realty (“VAR”) during the tax years 1986-95. See Compl. K116, 13. For fiscal year 1985, CDV reported losses on farming expenses of ap*161proximately $7.4 million and $196,000 in miscellaneous expenses. See Gov’t Ex. 1, App. B at B-5. William H. Schell and his wife, Ruby G. Schell3…