Barry v. United States

OPINION AND ORDER

BRUGGINK, Judge.

This action is one of a number of related proceedings brought pursuant to the Tax Equity and Fiscal Responsibility Act of 1982, 26 U.S.C. §§ 6221-6234 (2006) (“TEFRA”), by investors in a series of limited partnerships organized by American Agri-Corp., Inc. (“AMCOR”). These actions are brought by individual investing partners who are challenging assessments by the IRS flowing from an adjustment at the partnership level. The AMCOR partners assert three common claims for refund: (1) that the tax assessments were untimely due to the passage of the limitations…