Mandich v. United States

TEFRA; Settlement; Notice of Deficiency; Computational Adjustment; Affected Item; 26 U.S.C. § 465; At Risk Limitation; 26 U.S.C. § 469; Passive Activity Limitation; Doctrine of Variance

OPINION

BRUGGINK, Judge.

This is a suit for refund of federal income tax and interest. Taxpayers, Robert and Carol Mandich (“the Mandiches” or “taxpayers”), filed two suits here seeking refunds. The cases have been consolidated. Both cases involve the same settlement agreement between the Mandiches and the Internal Revenue Service (“IRS”) regarding their investment in the Greenberg Brothers Partnership # 12, also…