Opinion
20609-22S
11-16-2022
JEANNIE M. LAY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On November 10, 2022, respondent electronically filed a motion incorrectly titled Motion to Remove Lien/Levy Designation. In the motion, respondent asks that this Court remove the small tax case designation, as it appears the amount in dispute for petitioner's 2019 tax year exceeds $50,000.00, and thus that this case cannot proceed as a "small tax case" under Internal Revenue Code section 7463.
Upon due consideration of the foregoing, it is
ORDERED that respondent's above-referenced motion is recharacterized as a Motion to Remove Small Tax Case Designation. It is further
ORDERED that, on or before December 8, 2022, petitioner shall file an Objection, if any, to respondent's Motion to Remove Small Tax Case Designation. Failure to file an objection may result in the granting of respondent's motion.
The Court encourages all litigants to register for electronic access (eAccess) so that they may electronically file and view documents in their Tax Court cases. If you currently file in paper and/or receive paper service from the Court, you are encouraged to register for eAccess by emailing dawson.support@ustaxcourt.gov. If you did not electronically file the petition to commence your case and have not previously registered for eAccess, please do not attempt to electronically file documents in your case without first contacting dawson.support@ustaxcourt.gov.