Opinion
13244-23S
07-02-2024
CHRISTOPHER K. HARPER & CAROL G. HARPER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
The petition commencing the above-docketed matter was filed on August 17, 2023. In that document, petitioners Christopher K. Harper and Carol G. Harper elected to have this deficiency case conducted under the small tax case procedures. A review of the record, however, 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 §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 July 18, 2024, the Harpers 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.