Opinion
18705-22S
01-17-2023
HARBHEJ SINGH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Kathleen Kerrigan, Chief Judge.
In the petition filed to commence this case on August 23, 2022, petitioner elected to have this case conducted under the Court's small tax case procedures. On January 13, 2023, the parties filed a proposed stipulated decision for the Court's consideration. Upon further review of the record, however, it appears that the amount in dispute for petitioner's 2018 tax year exceeds $50,000.00, and thus this case cannot proceed as a "small tax case" under Internal Revenue Code section 7463.
Upon due consideration, it is
ORDERED that, on or before February 8, 2023, the parties shall show cause in writing why the Court should not issue an Order removing the small tax case designation in this case. We will hold the parties' proposed stipulated decision in abeyance until further direction by the Court.