In the current year, David and Debbie Wayland, both successful physicians, made cash investment for a limited partnership interest in a California berry farm. In addition to the cash obtained from the investors, management borrowed a substantial sum to purchase assets necessary for the farm’s operations. The Waylands’ investment adviser told them that their share of the tax loss in the first year alone would be in excess of their initial cash investment. This would be followed by several more years of losses. They feel confident that their interest in the berry farm is a sound investment. Identify the tax issues facing the Way lands.