Opinion
2405-21S
02-11-2022
Charles J. Blagburn Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
In the petition filed to commence this case, petitioner elected to have this case conducted under the Court's small tax case procedures. However, because the amount in dispute appeared to exceed $50,000.00, by Order to Show Cause issued March 25, 2021, the Court directed petitioner to show cause why the small tax case designation in this case should not be removed. See Internal Revenue Code section 7463. The Court received no response from petitioner. On January 21, 2022, the parties filed a proposed stipulated decision bearing the small tax case designation.
Upon due consideration, it is ORDERED that the Court's Order to Show Cause, issued March 25, 2021, is made absolute. It is further
ORDERED that the docket number of this case is amended by deleting the letter "S" and the Clerk of the Court is hereafter directed to process this case to trial or other disposition as a regular tax case. It is further
ORDERED that the proposed stipulated decision, filed January 21, 2022, is recharacterized as a stipulation of settlement.