Opinion
3271-23S
10-02-2023
STANLEY ZIONTS & HARRIETTE A. ZIONTS Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
By Order to Show Cause served March 14, 2023, the Court directed petitioners to 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 as a small tax case. To date, petitioners have failed to file a response to the Order to Show Cause.
Because the amount in dispute exceeds $50,000 for the taxable year 2020, this case cannot proceed as a small tax case. See I.R.C. § 7463(a)(1); Rules 170 and 171, Tax Court Rules of Practice and Procedure. That being so, it is
ORDERED that the Court's Order to Show Cause is hereby made absolute. It is further
ORDERED that the docket number of this case is amended by deleting the letter "S" therefrom, and the Clerk of the Court is hereafter directed to process this case to trial or other disposition as a regular tax case.