Opinion
3159-22S
03-03-2023
LINDA S. WALKER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden, Special Trial Judge
On February 8, 2023, the Court issued an Order directing the parties to show cause in writing why the small tax case designation in this case should not be removed. 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). On March 1, 2023, respondent filed a Response to Order to Show Cause. In it, respondent states that petitioner conceded a portion of the amount of the tax deficiency asserted in the notice of deficiency which yields an amount lower than Rule 170 requires. The amount of petitioner's tax remaining, along with the penalties is less than $50,000.
Premises considered, it is
ORDERED that the Court's Order to Show Cause, dated February 8, 2023, is hereby discharged.