Opinion
3203-21S
10-11-2022
PHILLIP CLAIBOURNE & MITZI CLAIBOURNE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On January 7, 2022, the Court issued in the above-docketed matter an Order To Show Cause directing petitioner to show cause, on or before January 27, 2022, why the Court should not issue an Order directing that the small tax case designation be removed in this case. No response to the Court's Order has been received from petitioners.
The small tax case procedures are only applicable to deficiency cases in which the amount in dispute for each taxable year is $50,000 or less. See section 7463(a)(1), Internal Revenue Code; Rules 170 and 171, Tax Court Rules of Practice and Procedure. Accordingly, upon due consideration and for cause, it is
ORDERED that the Court's Order To Show Cause, served January 7, 2022, is hereby made absolute. It is further
ORDERED that the Clerk of the Court shall delete the letter "S" from the docket number and other records of the Court in this case. It is further
ORDERED that the Proposed Stipulated Decision, filed January 6, 2022, is hereby deemed stricken from the Court's record in this case.