Opinion
6865-23S
01-02-2024
ASHLEY S. AEGERTER & JONATHAN CUMMING, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 4, 2023, the Court issued in the above-docketed matter an Order To Show Cause directing petitioners to show cause, on or before July 3, 2023, why the Court should not issue an Order directing that the small tax case designation be removed in this case. No response to the Court's Order has been received from petitioners.
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.
Accordingly, upon due consideration and for cause, it is
ORDERED that the Court's Order To Show Cause, served May 4, 2023, is hereby made absolute. It is further
ORDERED that the Clerk of the Court shall delete the letter "S" from the docket number and other records of the Court in this case.