Opinion
19372-22
04-05-2023
RACKWON SEONG & CHILOE J. SEONG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration of respondent's Motion To Remove Small Tax Case Designation, filed October 26, 2022, in the above-docketed matter, it appearing that the amounts in dispute for taxable years 2017 and 2018 exceed $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.), and petitioners having filed no objection to the granting thereof, it is
ORDERED that respondent's just-referenced motion is granted in 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. It is further
ORDERED, insofar as the record lacks any copy of a jurisdictional notice issued to petitioner Chiloe J. Seong, that on or before May 4, 2023, respondent shall file either: (1) An appropriate jurisdictional motion as to Chiloe J. Seong; and/or (2) a report establishing the basis or bases for the Court's jurisdiction as to Chiloe J. Seong and attaching thereto a copy of any supporting documentation.