Opinion
5734-24S
09-04-2024
BUGRAHAN SALTIK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan, Chief Judge
Further review of the record in this deficiency case shows that the amount in dispute for the taxable year 2021 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. § 7463(a)(1); Rules 170 and 171, Tax Court Rules of Practice and Procedure.
In consideration of the foregoing, it is
ORDERED that, on or before September 25, 2024, petitioner 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 that the proceedings not be conducted as a small tax case.