Opinion
6337-23S
06-20-2023
BUKI O. AJAYI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan, Chief Judge
On April 7, 2023, petitioner filed a Petition with the Court and elected to have this deficiency case conducted under the small tax case procedures. On June 9, 2023, respondent filed the Answer. Attached to the Answer is a copy of the notice of deficiency upon which this case is based. However, a review of the petition and the notice of deficiency shows that the amount in dispute for tax years 2020 and 2021 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 Code section 7463(a)(1); Rules 170 and 171, Tax Court Rules of Practice and Procedure.
Upon due consideration and for cause, it is
ORDERED that, on or before July 11, 2023, petitioner shall show cause, in writing, why the Court should not issue an Order directing the small tax case designation be removed in this case and that the proceeding not be conducted under the Small Tax Case Rules.
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