Opinion
18056-21S
10-04-2021
Gloria H. Darden, Deceased Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On September 23, 2021, the Court issued an Order To Show Cause directing petitioner to show cause in writing why the small tax case designation in this case should not be removed. For the small tax case election to be valid, the "amount of the deficiency placed in dispute" may not exceed $50,000 for any one taxable year. Sec. 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 679-680 (1987).
On September 27, 2021, petitioner filed a Response to the above Order To Show Cause. In that Response petitioner states that the amount she is disputing for tax year 2018 totals only $20,526, consisting of a deficiency in tax of $12,075, plus a substantial tax understatement penalty of $8,451. As that amount is less than the jurisdictional maximum for small tax cases, the Court concurs with petitioner's election to conduct this case as a small tax case.
Upon due consideration, it is
ORDERED that the Court's Order To Show Cause, issued September 23, 2021, is hereby discharged.
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