Opinion
3374-22S
12-12-2022
KEVIN J. MORRISON & JAYME J. MORRISON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan Chief Judge
Upon further review of the record in this case, the Court notes that the amount in dispute for the taxable year 2019 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 I.R.C. § 7463(a)(1); Rules 170 and 171, Tax Court Rules of Practice and Procedure.
Upon due consideration of the foregoing, it is
ORDERED that, on or before January 11, 2023, each party 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.