Opinion
24851-22S
06-20-2023
HUNG MINH LY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan Chief Judge
Upon further review of the record in this deficiency case, the Court notes that the amount in dispute for the taxable year 2018 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 I.R.C. § 7463(a)(1); Rules 170 and 171, Tax Court Rules of Practice and Procedure.
In consideration of the foregoing, it is
ORDERED that, on or before July 7, 2023, each party 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 that the proceedings not be conducted under the Small Tax Case Rules.