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Muskat v. Comm'r of Internal Revenue

United States Tax Court
Aug 5, 2022
No. 24352-21S (U.S.T.C. Aug. 5, 2022)

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.


Summaries of

Muskat v. Comm'r of Internal Revenue

United States Tax Court
Aug 5, 2022
No. 24352-21S (U.S.T.C. Aug. 5, 2022)
Case details for

Muskat v. Comm'r of Internal Revenue

Case Details

Full title:MICHAEL A. MUSKAT & JAMIE L. EDGAR, Petitioners v. COMMISSIONER OF…

Court:United States Tax Court

Date published: Aug 5, 2022

Citations

No. 24352-21S (U.S.T.C. Aug. 5, 2022)