Opinion
6594-24S
04-29-2024
BLAKE OVEREND & JAMISON A. OVEREND, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN CHIEF JUDGE.
On April 29, 2024, the Court issued in the above-docketed matter an Order To Show Cause directing petitioners to show cause, on or before June 28, 2024, why the Court should not issue an Order directing that the small tax case designation be removed in this case. No response to the Court's Order has been received from petitioner.
Later on the same April 29, 2024, petitioners rejoined with a Motion To Remove Small Tax Designation, requesting that the case be conducted under regular tax procedures.
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 April 29, 2024, is hereby made absolute. It is further
ORDERED that petitioners' just-referenced Motion To Remove Small Tax Designation is granted. 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 and shall process this case to trial or other disposition as a regular tax case.