Opinion
14262-21S
08-29-2022
BRICE LOBITZ & BECKY LOBITZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Cary Douglas Pugh Judge
The petition commencing the above-docketed case was filed on April 19, 2019. Upon review of the record, it appears that petitioners elected to have this deficiency case conducted under the small tax case procedures. However, the amount in dispute for the taxable year in issue 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. sec. 7463(a)(1); Rules 170 and 171, Tax Court Rules of Practice and Procedure. Upon due consideration and for cause, it is
ORDERED that, on or before September 26, 2022, the parties shall show cause in writing why the Court should not remove the small tax case designation and process this case to trial or other disposition as a regular tax case.