Opinion
11564-23S
09-12-2023
ROCIO LARA RODRIGUEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan Chief Judge
Further review of the record in this deficiency case shows that the amount in dispute for each of the taxable years at issue 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.
In consideration of the foregoing, it is
ORDERED that, on or before October 3, 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 as a small tax case.