Opinion
618-21S
02-03-2022
John P. Clifford Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Eunkyong Choi, Special Trial Judge
This case is calendared for trial at the April, 11, 2022, Baltimore, Maryland, Session of the Court.
On February 12, 2021, petitioner filed a Petition with the Court and elected to have this deficiency case conducted under the small tax case procedures. However, a review of the Petition 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 I.R.C. § 7463(a)(1); Rules 170 and 171, Tax Court Rules of Practice and Procedure.
Upon due consideration and for cause, it is
ORDERED that, on or before March 3, 2022, the parties shall show cause, in writing, why the Court should not remove the small tax case designation in this case.