Colvin v. Comm'r
United States Tax Court
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.
Read the full summary
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…
1Opinion of the Court
GARY LEE COLVIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Colvin v. Comm'r
No. 16557-04
United States Tax Court
T.C. Memo 2007-157; 2007 Tax Ct. Memo LEXIS 158; 93 T.C.M. (CCH) 1382;
June 19, 2007, Filed
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…
2Cases cited27 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Jones v. FlowersSupreme Court of the United States · 2006
22 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Gil v. United StatesDistrict Court, E.D. Pennsylvania · 2025