Opinion
3159-22S
02-08-2023
LINDA S. WALKER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER TO SHOW CAUSE
Diana L. Leyden, Special Trial Judge
This case is calendared for trial at the April 11, 2023, San Antonio, Texas, Trial Session of the Court.
The petition in this case was filed on January 25, 2022, challenging a deficiency in income tax for 2017. Petitioner 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 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 1, 2023, the parties shall show cause, in writing, why the Court should not remove the small tax case designation in this case.