Opinion
1239-23S
02-14-2023
FABRICIO MORAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan, Chief Judge
The petition commencing the above-docketed matter was filed on February 13, 2023. In that document, petitioners elected to have this deficiency case conducted under the small tax case procedures. However, a review of the record shows that the amount in dispute for one or more taxable years exceeds $50,000. 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.
Upon due consideration and for cause, it is
ORDERED that, on or before April 17, 2023 petitioners shall show cause in writing why the Court should not issue an Order directing that the small tax case designation be removed in this case and the proceedings not be conducted under the Small Tax Case Rules.