Opinion
21479-21S
03-22-2022
Permco, LLC, Timothy Perman, A Partner Other Than the Tax Matters Partner, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden, Special Trial Judge
This case is calendared for trial at the May 23, 2022, Denver, Colorado, Trial Session of the Court.
The petition in this case was filed on June 21, 2021, challenging a deficiency in income tax for 2017. Petitioner checked the box to have this case conducted under the "small tax case procedures." However, a review of the petition shows that the amount in dispute 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 I.R.C sec. 7463(a)(1); Rule 170 and 171, Tax Court Rules of Practice and Procedure. For cause, it
ORDERED that, on or before April 18, 2022, the parties shall show cause, in writing, why the Court should not remove the small tax case designation in this case.