Gary Lee Colvin - Page 1

                                 T.C. Memo. 2007-157                                  

                               UNITED STATES TAX COURT                                

                           GARY LEE COLVIN, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 16557-04.             Filed June 19, 2007.                  

                    R disallowed a majority of P’s claimed business                   
               expense deductions for 2000, due to a lack of                          
               substantiation, and determined a deficiency.  R mailed                 
               the notice of deficiency to four separate addresses.                   
               Each notice was returned to R.                                         
                    P claimed that he was a statutory employee                        
               pursuant to sec. 3121(d), I.R.C., for 2000.                            
                    Held:  The notice of deficiency is valid as                       
               petitioner received actual notice of the deficiency                    
               without prejudicial delay and filed timely a petition.                 
                    Held, further, P was not a statutory employee for                 
                    Held, further, The majority of R’s deficiency                     
               determinations are sustained.  P failed to meet the                    
               substantiation requirements of sec. 162, I.R.C., and                   
               where applicable, sec. 274, I.R.C., for most of the                    
               deductions, or portions thereof, that R disallowed.                    

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Last modified: November 10, 2007