Opinion
5552-23S
06-15-2023
DAVID JONATHAN MARKOVICH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On April 14, 2023, the Court issued in the above-docketed matter an Order To Show Cause directing petitioner to show cause, on or before June 13, 2023, why the Court should not issue an Order directing that the small tax case designation be removed in this case. No response to the Court's Order has been received from petitioner.
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 section 7463(a)(1), Internal Revenue Code; Rules 170 and 171, Tax Court Rules of Practice and Procedure. Accordingly, upon due consideration and for cause, it is
ORDERED that the Court's Order To Show Cause, served April 14, 2023, is hereby made absolute. It is further
ORDERED that the Clerk of the Court shall delete the letter "S" from the docket number and other records of the Court in this case. It is further
ORDERED that the place of trial for any proceedings held in this case shall be changed to San Francisco, California, a location at which the Court tries regular tax cases. It is further
ORDERED that the Proposed Stipulated Decision, filed June 13, 2023, is hereby deemed stricken from the Court's record in this case. The Court would expect the parties promptly to file a new Proposed Stipulated Decision reflecting the change to the docket number.