Opinion
15557-23S
12-29-2023
SARAH ANNE MCCRACKEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
The petition in this case was filed on October 2, 2023. On November 28, 2023, respondent filed a Motion to Remove Small Tax Case Designation, in which respondent states that petitioner left item 4 of the petition form blank.
On December 28, 2023, respondent filed a Response. However, further review indicates that this filing appears to be more akin to a supplement to respondent's motion. In this filing, respondent asserts that petitioner did indicate in the petition that she wants to conduct this case under small tax case procedures.
The Court is satisfied that the amount in dispute for each year falls under the $50,000 limit for small tax case status.
Upon due consideration, it is
ORDERED that respondent's Response, filed December 28, 2023, is recharacterized as respondent's Supplement to Motion to Remove Small Tax Case Designation. It is further
ORDERED that respondent's Motion to Remove Small Tax Case Designation, as supplemented, is denied.