Opinion
10073-23S
07-18-2023
TOM OLIVER MORRIS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On June 26, 2023, the Court issued in the above-docketed matter an Order To Show Cause directing petitioner to show cause why the Court should not issue an Order directing that the small tax case designation be removed in this case. Thereafter, on July 3, 2023, petitioner filed a response to the Order To Show Cause.
In that response, petitioner reaffirmed his claim that this proceeding should continue as a small tax case. As the basis for that stance, the response clarified and reiterated that petitioner sought to petition for redetermination only with respect to the 2021 taxable year, not the 2018 tax year. Insofar as the tax amounts reflected for 2021 on the underlying notice of deficiency do not exceed the $50,000 limit applicable to small tax cases pursuant to section 7463 of the Internal Revenue Code (I.R.C.), this matter may proceed as an "S" case.
The premises considered, it is
ORDERED that the Court's Order To Show Cause, served June 26, 2023, is discharged.