Opinion
23176-21S
07-13-2023
TRACEY L. BRADLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan Chief Judge.
The Petition in the above-docketed matter seeks review of a notice of deficiency for petitioner's 2015 tax year. Therein petitioner elected to have this case conducted under the Court's small tax case procedures.
On July 10, 2023, the parties filed a Proposed Stipulated Decision bearing a docket number which indicates petitioner's election for this case to be conducted as a small Tax Court case. Upon further review, however, it appears that the amount in dispute for petitioner's 2015 tax year exceeds $50,000.00, and that this case cannot therefore proceed as a "small tax case" under Internal Revenue Code section 7463.
Upon due consideration, it is
ORDERED that, on or before August 4, 2023, the parties shall show cause in writing why an Order should not be issued removing the small tax case designation in this case. The Court will hold the parties' Proposed Stipulated Decision in abeyance pending further direction by the Court.