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Ernst v. Comm'r of Internal Revenue

United States Tax Court
Aug 1, 2022
No. 16743-22S (U.S.T.C. Aug. 1, 2022)

Opinion

16743-22S

08-01-2022

DANA J. ERNST, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER TO SHOW CAUSE

Kathleen Kerrigan Chief Judge

The petition commencing the above-docketed matter was filed on July 31, 2022. In that document, petitioners elected to have this deficiency case conducted under the small tax case procedures. However, a review of the record shows that the amount in dispute for one or more taxable years 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 section 7463(a)(1), Internal Revenue Code; Rules 170 and 171, Tax Court Rules of Practice and Procedure.

Upon due consideration and for cause, it is

ORDERED that, on or before September 30, 2022 petitioners shall show cause in writing why the Court should not issue an Order directing that the small tax case designation be removed in this case and the proceedings not be conducted under the Small Tax Case Rules.


Summaries of

Ernst v. Comm'r of Internal Revenue

United States Tax Court
Aug 1, 2022
No. 16743-22S (U.S.T.C. Aug. 1, 2022)
Case details for

Ernst v. Comm'r of Internal Revenue

Case Details

Full title:DANA J. ERNST, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court:United States Tax Court

Date published: Aug 1, 2022

Citations

No. 16743-22S (U.S.T.C. Aug. 1, 2022)