Opinion
28479-21S
12-23-2021
Samina Raghid Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley, Chief Judge
On November 19, 2021, the Court issued an Order to Show Cause, directing petitioner to show cause why the small tax case designation should not be removed in this case. On December 20, 2021, a response to the Court's Order to Show Cause was filed by Raphael Grossman, CPA, on behalf of petitioner. As that response was not filed by petitioner or by a practitioner admitted to practice before this Court, we will strike that response from the Court's record. Furthermore, we will remove the small tax case designation as it appears to the Court that the amounts in dispute for each of the tax years at issue in this case exceed $50,000.00. Thus this case cannot proceed as a "small tax case" under Internal Revenue Code section 7463.
Upon due consideration, it is
ORDERED that the response to the Court's Order to Show Cause, filed on behalf of petitioner on December 20, 2021, is stricken from the Court's record in this case. It is further
ORDERED that the Court's Order to Show Cause, issued November 19, 2021, is made absolute. It is further
ORDERED that the docket number of this case is amended by deleting the letter "S" and the Clerk of the Court is directed to process this case to trial or other disposition as a regular tax case.