Opinion
27390-22S
01-24-2023
DAVID N. WARNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan Chief Judge.
The petition commencing the above-docketed matter was filed on December 12, 2022. In that document, petitioners elected to have this deficiency case conducted under the small tax case procedures. However, a review of the record shows that the amount in dispute for one or more taxable years 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 section 7463(a)(1), Internal Revenue Code; Rules 170 and 171, Tax Court Rules of Practice and Procedure.
Upon due consideration and for cause, it is
ORDERED that, on or before March 27, 2023 petitioners 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 the proceedings not be conducted under the Small Tax Case Rules.