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Burdette v. Comm'r of Internal Revenue

United States Tax Court
Aug 25, 2022
No. 33450-21S (U.S.T.C. Aug. 25, 2022)

Opinion

33450-21S

08-25-2022

KEVIN BURDETTE & NATALIA CORTEZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER TO SHOW CAUSE

Kathleen Kerrigan, Chief Judge.

The petition commencing the above-docketed matter was filed on December 10, 2021. In that document, petitioners elected to have this deficiency case conducted under the small tax case procedures. However, a review of the record shows that the amount in dispute for one or more taxable years exceeds $50,000. 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 section 7463(a)(1), Internal Revenue Code; Rules 170 and 171, Tax Court Rules of Practice and Procedure.

Upon due consideration and for cause, it is

ORDERED that, on or before September 14, 2022, petitioners 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 the proceedings not be conducted under the Small Tax Case Rules. It is further

ORDERED that the Proposed Stipulated Decision, filed August 19, 2022, is hereby deemed stricken from the Court's record in this case, pending resolution of the small tax case status.


Summaries of

Burdette v. Comm'r of Internal Revenue

United States Tax Court
Aug 25, 2022
No. 33450-21S (U.S.T.C. Aug. 25, 2022)
Case details for

Burdette v. Comm'r of Internal Revenue

Case Details

Full title:KEVIN BURDETTE & NATALIA CORTEZ, Petitioners v. COMMISSIONER OF INTERNAL…

Court:United States Tax Court

Date published: Aug 25, 2022

Citations

No. 33450-21S (U.S.T.C. Aug. 25, 2022)