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.