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Atwall v. Comm'r of Internal Revenue

United States Tax Court
Nov 16, 2022
No. 4969-22S (U.S.T.C. Nov. 16, 2022)

Opinion

4969-22S

11-16-2022

GURPREET K. ATWALL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER TO SHOW CAUSE

Eunkyong Choi Special Trial Judge.

On November 23, 2021, petitioner filed a Petition with the Court and elected to have this deficiency case conducted under the small tax case procedures. 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 review of the record in this case, it appears that the amount in dispute for one or more taxable years exceeded $50,000.00, and thus this case can not proceed as a "small tax case" under Internal Revenue Code section 7463.

Upon due consideration, it is hereby

ORDERED that, on or before December 15, 2022, respondent 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 that the proceedings should not be conducted under the Small Tax Case Rules.


Summaries of

Atwall v. Comm'r of Internal Revenue

United States Tax Court
Nov 16, 2022
No. 4969-22S (U.S.T.C. Nov. 16, 2022)
Case details for

Atwall v. Comm'r of Internal Revenue

Case Details

Full title:GURPREET K. ATWALL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court:United States Tax Court

Date published: Nov 16, 2022

Citations

No. 4969-22S (U.S.T.C. Nov. 16, 2022)