Opinion
738-22S
09-29-2022
MICHAELE WITCHER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden Special Trial Judge
This case is calendared for trial at the January 17, 2023, Baltimore, Maryland, Trial Session of the Court.
On January 24, 2022, petitioner 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 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 October 19, 2022, the parties shall show cause, in writing, why the Court should not remove the small tax case designation in this case.