Opinion
413-20S
08-30-2021
Richard E. Oney Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge.
On June 28, 2021 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. Subsequently, on July 21, 2021, petitioner filed a response explaining petitioner's earlier interpretation of the rules but concurring in an approach that would involve removal of the "S"..
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 section 7463(a)(1), Internal Revenue Code; Rules 170 and 171, Tax Court Rules of Practice and Procedure. Accordingly, upon due consideration and for cause, it is
ORDERED that the Court's Order To Show Cause, served June 28, 2021, is hereby made absolute. It is further
ORDERED that the Clerk of the Court shall delete the letter "S" from the docket number and other records of the Court in this case. It is further
ORDERED that the Proposed Stipulated Decision, filed June 24, 2021, is hereby deemed stricken from the Court's record in this case. The Court would expect the parties to file a new Proposed Stipulated Decision reflecting the corrected docket number.