Opinion
1555-23S
06-07-2023
MICHAEL WILLHIDE & JANIS WILLHIDE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On April 13, 2023, the Court issued an Order to Show Cause directing petitioners to show cause in writing why the Court should not issue an Order removing the small tax case designation in this case. Thereafter, on May 11, 2023, petitioners filed a Response to the Order to Show Cause. In that response, petitioners reaffirmed their claim that this proceeding should continue as a small tax case and demonstrated that the amount in dispute in this case does not exceed $50,000.00. Thus, as the amount in dispute does not exceed the $50,000.00 limit applicable to small tax cases pursuant to Internal Revenue Code section 7463, this matter may proceed as a small Tax Court case.
Upon due consideration of the foregoing, it is
ORDERED that the Court's above-referenced Order to Show Cause is discharged.