Opinion
21576-22S
10-19-2023
THEODORE A. BOLIN & TRACEY P. BOLIN,Petitioners v. COMMISSIONER OF INTERNAL REVENUE,Respondent
ORDER
Kathleen Kerrigan Chief Judge
This case is calendared for trial at the December 18, 2023, Tampa, Florida, Trial Session of the Court. A Petition commencing the above-docketed case was filed on September 26, 2022. The Bolins elected to have this deficiency case conducted under the small tax case procedures. On October 11, 2023, the parties filed a Settlement Stipulation and Proposed Stipulated Decision. The parties' Proposed Stipulation states that the parties agree that the Bolins are not liable for a deficiency in income, and the Bolins are due an overpayment in excess of $50,000 for tax year 2020. The small tax case procedures are only applicable to deficiency cases in which the amount in dispute or the amount of any claimed overpayment for the tax year is $50,000 or less. § 7463(a).
Unless otherwise indicated, statutory references are to the Internal Revenue Code, Title 26 U.S.C., in effect at all relevant times, and Rule references are to the Tax Court Rules of Practice and Procedure.
In view of the foregoing, and to give effect to the agreement of the parties in this case and for cause, it is
ORDERED that, on the Court's own motion, the caption of this case is amended by deleting the letter "S" from the docket number and the docket number is changed on the Court's records to "Docket No. 21576-22." It is further
ORDERED that proceedings in this case shall not be conducted under the Small Tax Case Rules.