Opinion
9431-23S
04-22-2024
SCOTT P. SUMNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Jennifer E. Siegel Special Trial Judge
Petitioner elected to have this deficiency case conducted under the Court's small tax case procedures. However, a review of the First Amendment to Answer, filed April 18, 2024, shows that the amounts in dispute for one or more taxable years may exceed $50,000. For the small tax case election to be valid, the "amount of the deficiency placed in dispute" may not exceed $50,000 for any one taxable year. Sec. 7463(a), (e); Kallich v. Commissioner, 89 T.C. 676, 679-680 (1987).
Upon due consideration and for cause, it is
ORDERED that, on or before May 13, 2024 petitioner shall show cause in writing why the Court should not issue an Order directing that the small tax case designation be removed from this case and the case stricken from the small tax case trial session of the Court scheduled to commence in San Diego, California on June 3, 2024.