Opinion
3620-23S
06-16-2023
ORDER
Kathleen Kerrigan, Chief Judge.
By Order to Show Cause served March 17, 2023, the Court directed petitioners to show cause in writing why the Court should not issue an order directing that the small tax case designation be removed in this case. To date, petitioners have failed to file a response.
Because the amount of the deficiency placed in dispute for the taxable year 2020 exceeds $50,000, this case is ineligible for the small tax case procedures. See I.R.C. § 7463(a)(1); Rules 170 and 171, Tax Court Rules of Practice and Procedure. That being so, it is
ORDERED that the Court's Order to Show Cause is hereby made absolute. It is further
ORDERED that the docket number of this case is amended by deleting the letter "S" therefrom, and the Clerk of the Court is hereafter directed to process this case to trial or other disposition as a regular tax case.