Shelton v. United States, No. 02-1042T (Fed. Cl. Sept. 23, 2008)

(partnership losses suspended under I.R.C. Sec. 465 by virtue of language in closing agreement remain subject to I.R.C. § 469 limit on passive activity losses against income from non-passive activity because closing agreement did not indicate that I.R.C. Sec. 469 would not apply to the suspended losses).