Opinion
14901-21
08-30-2021
Thomas C. Stewart & Barbara A. Stewart Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On August 16, 2021, the Court received a Request for Place of Trial which improperly seeks to designate Fresno, California, as the requested place of trial in this case. The Court's records reflect that this case is being conducted under the Court's regular tax case procedures, and not the small tax case procedures. Only cases conducted under the Court's small tax case procedures may be tried in Fresno, California.
Upon due consideration, it is
ORDERED that, on or before September 27, 2021, petitioners shall file either (1) a proper Request for Place of Trial designating a city at which this Court tries regular tax cases, or (2) a motion to add small tax case designation.
Petitioners are advised that if petitioners still wish to properly designate Fresno, California, as the requested place of trial in this case, petitioners should file a motion to add small tax case designation. Before doing so, petitioner should also decide whether they wish to have this case conducted under the regular tax case procedures or the small tax case procedures. General information concerning deciding whether to elect regular or small case procedures is posted under the "Starting A Case" tab in the Taxpayer Information section of the Court's website at www.ustaxcourt.gov.