Opinion
27390-22S
03-29-2023
DAVID N. WARNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On January 24, 2023, the Court issued in the above-docketed matter an Order To Show Cause directing petitioner to show cause, on or before March 27, 2023, why the Court should not issue an Order directing that the small tax case designation be removed in this case. Subsequently, on March 27, 2023, petitioner so filed a reply concurring that the small tax case procedures do not apply to the instant proceeding.
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 January 24, 2023, 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.