Opinion
1128-22S
01-24-2024
JEFFREY ALBERT PENN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE.
On December 4, 2023, the Court issued in the above-docketed matter an Order To Show Cause directing petitioner to show cause, on or before January 3, 2024, why the Court should not issue an Order directing that the small tax case designation be removed in this case. No response to the Court's Order has been received from petitioner. 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.
Accordingly, upon due consideration and for cause, it is
ORDERED that the Order to Show Cause is made absolute and the docket number of this case is amended by deleting the letter "S" therefrom. The Clerk of the Court is hereafter directed to process this case to trial or other disposition as a regular tax case.