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McCormick v. Comm'r of Internal Revenue

United States Tax Court
Aug 1, 2022
No. 12266-22S (U.S.T.C. Aug. 1, 2022)

Opinion

12266-22S

08-01-2022

BRIAN MCCORMICK & MERRISA MCCORMICK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan Chief Judge

On June 2, 2022, the Court issued an Order To Show Cause directing petitioners to show cause in writing why the small tax case designation in this case should not be removed. For the small tax case election to be valid, the "amount of the deficiency placed in dispute" may not exceed $50,000 for any one taxable year. Sec. 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 679-680 (1987).

On July 28, 2022, petitioners filed a Reply to the Court's order to show cause. In it, petitioners state that the "amount of deficiency in dispute" in this proceeding is significantly less than the jurisdictional maximum for small tax cases.

In view of the foregoing, it is ORDERED that the Court's Order To Show Cause, issued June 2, 2022, is hereby discharged.


Summaries of

McCormick v. Comm'r of Internal Revenue

United States Tax Court
Aug 1, 2022
No. 12266-22S (U.S.T.C. Aug. 1, 2022)
Case details for

McCormick v. Comm'r of Internal Revenue

Case Details

Full title:BRIAN MCCORMICK & MERRISA MCCORMICK, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Aug 1, 2022

Citations

No. 12266-22S (U.S.T.C. Aug. 1, 2022)