Nasso v. Comm'r of Internal Revenue, 8643-22S

CourtUnited States Tax Court
Writing for the CourtKathleen Kerrigan Chief Judge
PartiesVINCENT NASSO & MARIA NASSO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Decision Date17 June 2022
Docket Number8643-22S

VINCENT NASSO & MARIA NASSO, Petitioners
v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

No. 8643-22S

United States Tax Court

June 17, 2022


ORDER

Kathleen Kerrigan Chief Judge

On April 20, 2022, the Court issued in the above-docketed matter an Order To Show Cause directing petitioners to show cause why the Court should not issue an Order directing that the small tax case designation be removed in this case. On June 10, 2022, a response to the Court's Order was filed on petitioners' behalf. Therein, petitioners indicated continued disagreement with the taxes asserted by the Internal Revenue Service (IRS). Rather, petitioners suggested that the amount owing would be less than $50, 000 once an amended return had been processed and payments accepted.

Given the foregoing, it is appears that determinations by the IRS in excess of $50, 000 remain in dispute at this juncture. The $50, 000 limit refers to the amount challenged, not the amount that will ultimately be owed. There may also be some confusion about the significance of various Tax Court procedures and designations. Petitioners is therefore advised that this case will proceed and that opportunity will be afforded for petitioner to present to the Tax Court evidence and/or argument in support of petitioners' position. The case will simply go forward here as a "regular" case and will not be designated as a "small tax" case.

Accordingly and for cause, it is

ORDERED that the Court's Order To Show Cause, dated April 20, 2022, 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.

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