Opinion
3374-24S
07-17-2024
HENRY ZUNIGA GUEVARA & DIANA J. CORNEJO LOAYZA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On June 3, 2024, the Court issued an Order to Show Cause. That Order directed petitioner(s) to show cause in writing why the Court should not issue an Order removing the small tax case designation, as it appears that the amount in dispute for each tax year at issue in this case exceeds $50,000.00 and, therefore, this case cannot proceed as a "small tax case" under Internal Revenue Code section 7463. No response has been received from petitioner(s).
Upon due consideration of the foregoing, it is
ORDERED that the Court's above-referenced Order to Show Cause is made absolute. It is further
ORDERED that the docket number of this case is amended by deleting the letter "S" and the Clerk of the Court is hereafter directed to process this case to trial or other disposition as a regular tax case.