Opinion
37559-21S
02-23-2023
TIMOTHY SLATER & STEPHANIE SLATER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Diana L. Leyden Special Trial Judge
This case is calendared for trial at the June 15, 2023, Cheyenne, Wyoming, remote Trial Session of the Court.
The petition in this case was filed on December 21, 2021, challenging a deficiency in income tax for 2018 and 2019. Petitioners checked the box to have this case conducted under the "small tax case procedures." However, a review of the petition shows that the amount in dispute for the taxable year 2018 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 sec. 7463(a)(1); Rule 170 and 171, Tax Court Rules of Practice and Procedure. For cause, it
ORDERED that, on or before March 23, 2023, the parties shall show cause, in writing, why the Court should not remove the small tax case designation in this case.