Opinion
23116-22S
08-18-2023
ROSA SALGAD GARCIA-MENDEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan, Chief Judge.
The Petition in the above-docketed matter seeks review of a notice of deficiency for petitioner's 2019 and 2020 tax years. Therein petitioner elected to have this case conducted under the Court's small tax case procedures.
On August 15, 2023, the parties filed a Proposed Stipulated Decision bearing a docket number which indicates petitioner's election for this case to be conducted as a small Tax Court case. Upon further review, however, it appears that the amount in dispute for petitioner's 2019 tax year exceeds $50,000.00, and that this case cannot therefore proceed as a "small tax case" under Internal Revenue Code section 7463.
Upon due consideration, it is
ORDERED that, on or before September 8, 2023, the parties shall show cause in writing why an Order should not be issued removing the small tax case designation in this case. The Court will hold the parties' Proposed Stipulated Decision in abeyance pending further direction by the Court.