The Lay suit and many others filed this week and in recent months concern investments in limited partnerships in farms in the United States and Mexico that were managed by a California firm called Amcor.

The money invested by thousands of individuals around the country was to be used to finance the purchase of the properties and tending of crops. The Internal Revenue Service began an investigation of Amcor in 1989 and determined that many partnership investors needed to pay more in taxes and penalties.

Investors have been fighting the IRS' claims for several years, particularly the penalty fees attached to the rulings, said Houston attorney Thomas Redding, who filed the suits on behalf of investors. He notes that Congress abolished those types of penalties in 1989.

Redding said a handful of cases are working their way through the civil and appeals courts in Texas will be serve as test cases for lawsuits like those filed on behalf of the Lays.

The Lays' claims of about $130,000 are modest compared to those of other investors, who are seeking to recover more than $300 million, Redding said.

-- Tom Fowler, the Houston Chronicle