Opinion
9057-23S
09-11-2023
JAZMINE D. DAILEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On June 7, 2023, the Court issued an Order to Show Cause directing petitioners to show cause why the Court should not issue an Order directing that the small tax case designation be removed in this case. On August 14, 2023, petitioner filed a Response, in which petitioner asks to remain with the small case procedures. Petitioner's concern appears to be that she would like to settle this case at the appeals office and cannot afford to engage someone to represent her. However, the amount of deficiency in the notice of deficiency issued for tax year 2020 exceeds $50,000. Petitioner does not suggest that she intends to concede any part of the deficiency determined. 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.
Accordingly and for cause, it appearing that this case is ineligible to be conducted under the small tax case procedures, it is
ORDERED that the Court's Order to Show Cause, dated June 7, 2023, is hereby made absolute. It is further
ORDERED that the Clerk of the Court shall delete the letter "S" from the docket number and other records of the Court in this case.
Petitioner is directed the Court's website at www.ustaxcourt.gov, where there is guidance for petitioners and a list of clinics and pro bono programs.