Opinion
1121-23SL
09-30-2024
VINCENT EDWARD MANDLEY & YOLANDA B. MANDLEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Zachary S. Fried, Special Trial Judge
Because the amount of petitioners' unpaid Federal tax liabilities exceed the limitations set forth in I.R.C. § 7463(f)(2), petitioners' election under that section in this I.R.C. § 6330(d) case is discontinued. That being so, it is
ORDERED that respondent's Motion for Leave to File Out of Time Motion to Remove Small Tax Case Designation, filed September 11, 2024, is granted, and respondent's Motion to Remove Small Tax Case Designation shall be filed as of the date of service of this Order. It is further
ORDERED that respondent's Motion to Remove Small Tax Case Designation is granted. It is further
ORDERED that the Clerk of the Court delete the letter "S" from the docket number in this case and amend the Court's records to reflect that deletion. It is further
ORDERED that further proceedings in this case are not subject to I.R.C. § 7463.