Opinion
1754-23S
04-19-2023
DAVID SCOTT RUTKOWSKI, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On April 7, 2023, respondent filed in the above-docketed matter a Motion To Remove Small Tax Case Designation, on the ground that the amount in dispute (i.e., the amount that petitioner challenges or believes is wrong) for taxable year 2019 exceeds $50,000.00, such that this case cannot proceed as a "small tax case" under section 7463 of the Internal Revenue Code (I.R.C.).
Upon due consideration, it is
ORDERED that, on or before May 10, 2022, petitioner shall file an objection, if any, to respondent's just-referenced motion. Failure to comply with this Order may result in the granting of respondent's motion or other appropriate action by this Court.