Opinion
3785-23S
05-24-2023
SHAWN A. FITZPATRICK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 21, 2023, the Court issued an Order to Show Cause. That Order directed petitioner to show cause in writing why the Court should not issue an Order removing the small tax case designation, as it appears that the amount in dispute for tax year 2020 exceeds $50,000.00 and, therefore, this case cannot proceed as a "small tax case" under Internal Revenue Code section 7463. No response has been received from petitioner.
Upon due consideration of the foregoing, it is ORDERED that the Court's above-referenced Order to Show Cause is made absolute. It is further
ORDERED that the docket number of this case is amended by deleting the letter "S" and the Clerk of the Court is hereafter directed to process this case to trial or other disposition as a regular tax case. It is further
ORDERED that the parties' Proposed Stipulated Decision, filed May 12, 2023, which references this case's previous docket number is stricken from the Court's record, It is further
ORDERED that, on or before June 23, 2023, the parties shall file a corrected Proposed Stipulated Decision.