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deficiency case, the dollar limit for using small tax case
procedures under section 7463(a) is determined on a per-year
basis. However, in Schwartz v. Commissioner, supra at 12, we
held that the $50,000 limit in section 7463(f)(2), providing for
small tax case procedures in a section 6330 collection case,
“refers to the total amount of unpaid tax which the Commissioner
has determined to collect. The fact that the unpaid tax for each
year, period, or taxable event does not exceed $50,000 is
irrelevant.” In Schwartz, we reasoned that
The dollar limit is clearly expressed in terms of the
“case” of “an appeal * * * to the Tax Court of a
determination in which the unpaid tax does not exceed
$50,000.” The dollar limit refers to the amount of
unpaid tax the collection of which is being challenged.
The dollar limit in section 7463(f)(2) is a condition
that must be met before a section 6330 collection case
can qualify to be conducted as a small tax case in the
same manner as a case described in subsection (a). If
Congress had intended that the $50,000 limitation in
subsection (f)(2) be applied to the amount of tax for
each year, period, or taxable event, it surely knew how
to do so; and it presumably would have used the same
terminology as in section 7463(a).
Id. at 11 (fn. ref. omitted).
Paragraph (1) of section 7463(f) is similar to paragraph (2)
in this respect. The dollar limit in paragraph (1) is expressed
in terms of “a petition to the Tax Court under section 6015(e) in
which the amount of relief sought does not exceed $50,000”. The
statute clearly refers to the amount of relief sought in a
petition. We therefore hold that the $50,000 limit in section
7463(f)(1) refers to the total amount of relief sought in the
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