Opinion
15693-23S
11-14-2023
PAMELA L. LOVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On November 13, 2023, respondent filed in the above-docketed matter a Motion To Remove Small Tax Case Designation, on the ground that: "Petitioner electronically filed a petition with this Court on October 5, 2023, and failed to check any box under paragraph 4 relating small tax case procedures." However, review of the eFiled petition clearly shows a checkmark in the box for electing small tax case procedures. Moreover, the amount in dispute would appear to qualify for under section 7463 of the Internal Revenue Code (I.R.C.).
Accordingly, upon due consideration, it is
ORDERED that, on or before November 28, 2023, respondent shall file a supplement to the just-referenced motion, clarifying the basis for the relief sought.