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.