Opinion
27085-21S
11-18-2021
Patrick K. Windley & Julie I. Windley Petitioners v. Commissioner of Internal Revenue Respondent
ORDER TO SHOW CAUSE
Maurice B. Foley, Chief Judge
On October 18, 2021, petitioners filed a Petition with the Court and elected to have this deficiency case conducted under the small tax case procedures. However, a review of the Petition shows that the amount in dispute for one or more taxable years 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 Code section 7463(a)(1); Rules 170 and 171, Tax Court Rules of Practice and Procedure.
Upon due consideration and for cause, it is
ORDERED that, on or before December 16, 2021, petitioners shall show cause, in writing, why the Court should not issue an Order directing that the small tax case designation be removed in this case and that the proceedings not be conducted under the Small Tax Case Rules.