Opinion
13128-20SL
03-22-2022
Christopher T. Walker & Anna F. Walker Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Kathleen Kerrigan Judge.
On November 12, 2020, petitioners filed the petition to commence this case, seeking review of a notice of deficiency issued for petitioners' 2014, 2015, and 2016 tax years. In that petition, petitioners indicated that they wish this case to be conducted under the Court's small tax case procedures. On March 9, 2022, respondent filed a Motion To Remove Small Tax Case Designation, asserting therein that as the amount in dispute for the tax years at issue exceeds $50,000.00, this case cannot proceed as a "small tax case" under Internal Revenue Code section 7463.
Upon due consideration, it is
ORDERED that respondent's above-referenced motion is granted in that the docket number of this case is amended by deleting the letter "S" and the Clerk of the Court is hereafter directed to process this case to trial or other disposition as a regular tax case.