Opinion
24879-22S
01-30-2023
AUGUSTIN A. RICHARD III & MELINDA M. RICHARD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On November 29, 2022, the Court issued an Order to Show Cause. That Order directed petitioners to show cause in writing why the Court should not issue an Order removing the small tax case designation, as it appeared that the amount in dispute for petitioners' 2019 tax year may exceed $50,000.00 and, if so, this case could not proceed as a "small tax case" under Internal Revenue Code section (I.R.C.) 7463. On January 26, 2023, the parties filed a Status Report. Upon review of the petition and the parties' Status Report, it appears that in this case petitioners only dispute the penalty under section 6662, which amount does not exceed $50,000.00.
Upon due consideration of the foregoing, it is ORDERED that the Court's Order to Show Cause, issued November 29, 2022, is discharged.