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
2000.
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