If you are experiencing difficulties with the IRS, know your rights as a taxpayer. Read the Taxpayer Bill of Rights (https://www.irs.gov/pub/irs-pdf/p1.pdf). Also consider contacting the National Taxpayer Advocate service (https://taxpayeradvocate.irs.gov/contact-us). And you may want to engage a tax professional who can represent you in this matter.
Rules that limit the deduction of losses from passive activities to income from other passive activities. Passive activities include investment rental operations or businesses in which you do not materially participate.