Opinion
9150-24S
07-11-2024
CAROL MURPHY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
By Order to Show Cause served June 5, 2024, the Court directed petitioner to 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 as a small tax case. On July 3, 2024, the Court received and filed a response from petitioner. Petitioner states that she disagrees with the removal of the small tax case designation; however, petitioner further indicates that she disputes respondent's determinations in the notice of deficiency that she was issued for tax year 2021. The notice of deficiency determines a deficiency and a penalty under I.R.C. section 6662(a) that exceed $50,000.00.
Because the amount in dispute exceeds $50,000 for the taxable year 2021, this case cannot proceed as a small tax case. See I.R.C. § 7463(a)(1), (e); Rules 170 and 171, Tax Court Rules of Practice and Procedure.
That being so, it is
ORDERED that the Court's Order to Show Cause is hereby made absolute. It is further
ORDERED that the docket number of this case is amended by deleting the letter "S" therefrom, and the Clerk of the Court is hereafter directed to process this case to trial or other disposition as a regular tax case.