Opinion
8274-20S
10-06-2021
Adelowo Adebiyi Petitioner v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
Maurice B. Foley Chief Judge
On July 10, 2020, the Court received and filed the petition to commence this case, in which petitioner seeks review of a notice of deficiency issued to petitioner for the 2017 tax year. Petitioner elected to have this case conducted under the Court's small tax case procedures. Upon further review, however, it appears that the amount in dispute for petitioner's 2017 tax year exceeds $50, 000.00, and thus that this case cannot proceed as a "small tax case" under Internal Revenue Code section 7463.
Upon due consideration, it is
ORDERED that, on or before October 28, 2021, the parties shall show cause in writing why the small tax case designation in this case should not be removed.
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