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Diaz v. Comm'r of Internal Revenue

United States Tax Court
Sep 28, 2021
No. 23626-21S (U.S.T.C. Sep. 28, 2021)

Opinion

23626-21S

09-28-2021

Maria E. Diaz Petitioner v. Commissioner of Internal Revenue Respondent


ORDER TO SHOW CAUSE

MAURICE B. FOLEY, CHIEF JUDGE

On June 29, 2021, the petitioner filed a Petition with the Court and elected to have this deficiency case conducted under the small tax case procedures. However, a review of the Petition shows that the amount in dispute for one or more taxable years exceeds $50,000. 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 Code section 7463(a)(1); Rules 170 and 171, Tax Court Rules of Practice and Procedure.

Upon due consideration and for cause, it is

ORDERED that, on or before November 5, 2021, petitioner shall show cause, in writing, why the Court should not issue an Order directing that the small tax case designation be removed in this case and that the proceedings not be conducted under the Small Tax Case Rules.

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Summaries of

Diaz v. Comm'r of Internal Revenue

United States Tax Court
Sep 28, 2021
No. 23626-21S (U.S.T.C. Sep. 28, 2021)
Case details for

Diaz v. Comm'r of Internal Revenue

Case Details

Full title:Maria E. Diaz Petitioner v. Commissioner of Internal Revenue Respondent

Court:United States Tax Court

Date published: Sep 28, 2021

Citations

No. 23626-21S (U.S.T.C. Sep. 28, 2021)