Opinion
1533-24S
01-30-2024
MICHAEL J. PICCIONE, 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 January 26, 2024. 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 1, 2024 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.