Opinion
31879-21S
03-18-2022
Patrick Jordan Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
On October 6, 2021, petitioner filed the petition to commence this case, seeking review of a notice of deficiency issued for petitioner's 2017 tax year. In that petition, petitioner indicated that he wishes this case to be conducted under the Court's small tax case procedures. On January 19, 2022, respondent filed a Motion To Remove Small Tax Case Designation, asserting therein that as the amount in dispute for petitioner's 2017 tax year exceeds $50,000.00, this case cannot proceed as a "small tax case" under Internal Revenue Code section 7463.
On February 9, 2022, petitioner filed an objection to respondent's motion. Petitioner's objection, however, fails to address respondent's assertions concerning whether this case qualifies to be conducted under the Court's small tax case procedures.
Upon due consideration of the foregoing, it is
ORDERED that respondent's above-referenced motion is granted in 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.