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.