Opinion
24352-21S
08-05-2022
MICHAEL A. MUSKAT & JAMIE L. EDGAR, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Adam B. Landy, Special Trial Judge
A petition commencing the above-docketed case was filed on September 27, 2021. Petitioners elected to have this deficiency case conducted under the small tax case procedures. However, a review of respondent's answer shows that the amount in dispute for taxable year 2018 exceeds $50,000. The small tax case procedures are only applicable to deficiency cases in which the amount in dispute for the taxable year is $50,000 or less. See I.R.C. § 7463(a)(1); Rules 170 and 171, Tax Court Rules of Practice and Procedure.
Upon due consideration and for cause, it is
ORDERED that, on or before September 2, 2022, petitioners and respondent shall each 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.