From Casetext: Smarter Legal Research

Cohen v. Comm'r of Internal Revenue

United States Tax Court
Aug 4, 2022
No. 24626-21S (U.S.T.C. Aug. 4, 2022)

Opinion

24626-21S

08-04-2022

ARIYE M. COHEN & REBECCA C. COHEN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Diana L. Leyden, Special Trial Judge

This case is calendared for trial at the November 7, 2022, Seattle, Washington, Trial Session of the Court.

The petition in this case was filed on July 6, 2021, challenging a deficiency in income tax for 2018. Petitioners elected to have this case conducted under the "small tax case procedures." However, a review of the Petition shows that the amount in dispute 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 sec. 7463(a)(1); Rule 170 and 171, Tax Court Rules of Practice and Procedure. For cause, it

ORDERED that, on or before August 23, 2022, the parties shall show cause, in writing, why the Court should not remove the small tax case designation in this case and that the proceeding not be conducted under the Small Tax Case Rules.


Summaries of

Cohen v. Comm'r of Internal Revenue

United States Tax Court
Aug 4, 2022
No. 24626-21S (U.S.T.C. Aug. 4, 2022)
Case details for

Cohen v. Comm'r of Internal Revenue

Case Details

Full title:ARIYE M. COHEN & REBECCA C. COHEN, Petitioners v. COMMISSIONER OF INTERNAL…

Court:United States Tax Court

Date published: Aug 4, 2022

Citations

No. 24626-21S (U.S.T.C. Aug. 4, 2022)