Opinion
11564-23S
09-28-2023
ROCIO LARA RODRIGUEZ, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
By Order to Show Cause served September 12, 2023, the Court directed each party to 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 that the proceedings not be conducted as a small tax case. On September 20 and 28, 2023, petitioner and respondent, respectively, filed a Response to Order to Show Cause.
Because the amount in dispute exceeds $50,000 for each of the taxable years at issue, this case cannot proceed as a small tax case. See I.R.C. § 7463(a)(1); Rules 170 and 171, Tax Court Rules of Practice and Procedure. That being so, it is
ORDERED that the Court's Order to Show Cause is hereby made absolute. It is further
ORDERED that the docket number of this case is amended by deleting the letter "S" therefrom, and the Clerk of the Court is hereafter directed to process this case to trial or other disposition as a regular tax case.