Albert R. Matthews - Page 4

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          taxable income from his law practice was $214,736, $164,008, and            
          $161,332, respectively.1                                                    
               In addition to practicing law, petitioner also is engaged in           
          rodeo and horse-training activities (horse activity) that are the           
          subject of this case.  Petitioner raises and trains horses on his           
          ranch in Muskogee, Oklahoma, where he also resides.  For the                
          years 1991 and 1993 through 1999 (data is not available for                 
          1992), petitioner reported income and expenses and claimed losses           
          from his horse activity as follows:                                         
                      Rodeo & Horse   Rodeo & Horse    Rodeo & Horse                  
            Year      Gross Income       Expenses         Losses                      
            1991        $17,763         $92,116         ($74,353)                     
            1992                Data not available                                    
            1993          6,264          66,211          (59,947)                     
            1994          3,130          58,983          (55,853)                     
            1995         15,195          53,622          (38,427)                     
            1996          4,625          45,736          (41,111)                     
            1997          1,016          60,837          (59,821)                     
            1998          8,212          52,477          (44,265)                     
            1999          4,616          47,377          (42,761)                     
              Total      60,821         477,359         (416,538)                     
               As shown above by the table, petitioner claimed horse                  
          activity losses of $59,821, $44,265, and $42,761 on Schedule C,             



               1  The parties stipulated that these amounts were earned               
          from practicing law.  However, a review of Schedules E,                     
          Supplemental Income and Loss, for the years in issue shows that,            
          while most of petitioner’s income consisted of partnership                  
          distributions from the Bonds Matthews Law Firm, petitioner also             
          received Schedule E income in the form of royalties from TEPPCO             
          Crude Oil, LLC, and GM Oil Prop, Inc., partnership income or loss           
          from the Matthews, Bonds Jr., & Hayes Building Partnership, and             
          income or loss from an S corporation called Hopes & Dreams Ltd.             




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