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Petrillo v. Comm'r of Internal Revenue

United States Tax Court
Jul 2, 2024
No. 16211-23S (U.S.T.C. Jul. 2, 2024)

Opinion

16211-23S

07-02-2024

MICHAEL G. PETRILLO & RHONDA L. PETRILLO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan Chief Judge.

By Order to Show Cause served October 16, 2023, the Court directed petitioners 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. To date, petitioners have failed to file a response to the Order to Show Cause.

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); 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.


Summaries of

Petrillo v. Comm'r of Internal Revenue

United States Tax Court
Jul 2, 2024
No. 16211-23S (U.S.T.C. Jul. 2, 2024)
Case details for

Petrillo v. Comm'r of Internal Revenue

Case Details

Full title:MICHAEL G. PETRILLO & RHONDA L. PETRILLO, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Jul 2, 2024

Citations

No. 16211-23S (U.S.T.C. Jul. 2, 2024)