Opinion
1821-22S
04-25-2022
RYAN MATTHEW GRANT & BRANDI MICHELLE HALE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley, Chief Judge.
On February 14, 2021, the Court issued an Order To Show Cause directing petitioners to show cause in writing why the small tax case designation in this case should not be removed. For the small tax case election to be valid, the "amount of the deficiency placed in dispute" may not exceed $50,000 for any one taxable year. Sec. 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 679-680 (1987).
On March 30, 2022, petitioners filed a Reply to the Court's order to show cause. In it, petitioners state that the "amount of deficiency in dispute" in this proceeding is significantly less than the jurisdictional maximum for small tax cases. On April 22, 2022, respondent filed a Response to petitioners' reply. Among other things, in his Response respondent states he does not object to this case being conducted under the small tax case procedures.
Premises considered, it is ORDERED that the Court's Order To Show Cause, issued February 14, 2021, is hereby discharged.