Opinion
19185-22S
04-25-2023
TONY T. JOHNSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On April 4, 2023, the parties filed for the Court's consideration a Proposed Stipulated Decision. The docket number appearing in the Proposed Stipulated Decision includes an "S", indicating petitioner's election to have this case conducted as a small Tax Court case. On April 7, 2023, the Court issued an Order to Show Cause. That Order directed the parties to show cause in writing why the Court should not issue an Order removing the small tax case designation, as it appeared that the amount in dispute for tax year 2020 exceeds $50,000.00 and, therefore, this case could not proceed as a "small tax case" under Internal Revenue Code section 7463.
On April 18, 2023, respondent filed a Response to the Court's Order to Show Cause, stating therein that the small tax case designation should be removed in this case and also that petitioner has no objection to the removal of the small tax case designation.
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 as a regular tax case. It is further
ORDERED that the parties' Proposed Stipulated Decision, filed April 4, 2023, is stricken from the Court's record. It is further
ORDERED that, on or before May 19, 2023, the parties shall file a revised Proposed Stipulated Decision.