Albert R. Matthews - Page 3

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               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  When he filed his                   
          petition, petitioner resided in Muskogee, Oklahoma.                         
              Respondent determined deficiencies in petitioner’s Federal              
          income taxes, additions to tax under section 6651(a)(1), and                
          accuracy-related penalties under section 6662(a) as follows:                
                                         Additions to Tax     Penalties               
              Year      Deficiency       Sec. 6651(a)(1)     Sec. 6662(a)             
              1997       $26,097            $6,524.26        $5,146.20                
              1998        19,113             4,778.25         3,341.80                
              1999        18,173             1,750.95         3,329.80                
               The issues for decision are:  (1) Whether petitioner engaged           
          in his rodeo and horse-training activity during 1997-99 with the            
          objective of making a profit within the meaning of section 183,             
          (2) whether petitioner is liable for additions to tax under                 
          section 6651(a)(1) for filing his tax returns after the due                 
          dates, and (3) whether petitioner is liable for accuracy-related            
          penalties under section 6662(a).                                            
                                     Background                                       
               Petitioner is an attorney and partner with the Bonds                   
          Matthews Law Firm in Muskogee, Oklahoma.  Petitioner’s law                  
          practice is concentrated primarily in litigation and plaintiff              
          personal injury law.  In 1997, 1998, and 1999, petitioner’s                 









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