- 17 - Commissioner, T.C. Memo. 2003-98 (citing St. Joseph Lease Capital Corp. v. Commissioner, 235 F.3d 886, 891-892 (4th Cir. 2000), affg. T.C. Memo. 1996-256; Estate of Biskis v. Commissioner, T.C. Memo. 2001-94; Estate of Citrino v. Commissioner, T.C. Memo. 1987-565). Petitioner had actual notice of the deficiency as he requested, and received, a copy of the notice of deficiency from the IRS TAS. Petitioner filed a petition that was timely and, therefore, did not suffer prejudicial delay. Accordingly, the Court concludes that the notice of deficiency is valid, and this Court has jurisdiction. III. Statutory Employee A. General Rules A statutory employee may properly reflect business income and expenses in full on Schedule C of Form 1040, and thereby avoid the Schedule A, Itemized Deductions, limitations on the deduction of employee business expenses and the phaseout of 14(...continued) obstruction of justice by intentionally misaddressing the notice of deficiency sent to the Round Rock, Texas, address. The Court concludes that these allegations are unfounded, frivolous, and meritless. If anything, the evidence indicates that respondent, by sending four differently addressed notices of deficiency, was very interested in ensuring that petitioner received the notice of deficiency. Additionally, petitioner alleges that he did not receive a complete copy of the notice of deficiency until 9 months after filing his petition. However, petitioner attached a complete copy of the notice of deficiency to his filed petition.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: November 10, 2007