Opinion
7400-23S
06-06-2024
MELISSA A. SULLIVAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On May 11, 2024, the Court issued in the above-docketed matter an Order To Show Cause directing petitioner to show cause why the Court should not issue an Order directing that the small tax case designation be removed in this case. No response to the Court's Order has been received from petitioner. Rather, the parties have filed a Proposed Stipulated Decision, albeit one with a misspelling in the caption, suggesting that petitioner does not intend at this juncture to contest the removal of the small tax case status.
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 section 7463(a)(1), Internal Revenue Code; Rules 170 and 171, Tax Court Rules of Practice and Procedure. Accordingly, upon due consideration and for cause, it is
ORDERED that the Court's Order To Show Cause, served May 11, 2024, is hereby made absolute. It is further
ORDERED that the Clerk of the Court shall delete the letter "S" from the docket number and other records of the Court in this case. It is further
ORDERED that the Proposed Stipulated Decision, filed June 5, 2024, is hereby deemed stricken from the Court's record in this case. The Court would expect the parties promptly to file a revised version correcting the caption and the Docket No.