Albert R. Matthews - Page 12

                                       - 11 -                                         
          activity, and did not maintain an inventory accounting for each             
          of his horses.                                                              
               His testimony indicates that petitioner’s primary                      
          expectation for a profit comes from the anticipated appreciation            
          in the value of his assets, his ranch property and improvements             
          and his horses.  Because of the absence of supporting                       
          documentation, such as an outside appraisal, records from the               
          sale of comparable ranch property in the area, or receipts for              
          the cost of the improvements to his ranch, petitioner failed to             
          substantiate the value of his ranch.  Furthermore, in response to           
          direct questioning from this Court, petitioner admitted that the            
          current value of his ranch is probably less than the cumulative             
          amount of losses he has claimed from his horse activity.                    
          Petitioner speculated that his property will continue to                    
          appreciate tremendously in the future, but he did not introduce             
          any objective evidence of projected increases in property values            
          in the area of his ranch for the Court to consider.  As to the              
          values of his horses, petitioner’s 1997 return showed a sale of a           
          horse at a loss of $7,500, undermining his own unverified and               
          self-serving testimony that he expects to profit from the sale of           
          his horses.  Petitioner failed to substantiate the value of his             
          assets or the likelihood of any appreciation in the value of                
          these assets.  The record clearly shows that petitioner’s horse             
          activity has produced a history of losses.  For each year since             






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: May 25, 2011