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Theodore C. and Denise M. Schwartz, pro sese.
Michele E. Craythorn, for respondent.
OPINION
RUWE, Judge: This case is before the Court for judicial
review of a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 (determination letter).
The petition was filed pursuant to section 6330(d).1 Petitioners
requested that this case be conducted under section 7463, which
provides for what are commonly referred to as “small tax case” or
“S case” procedures. There was no objection to this request, and
the case was designated and tried as a small tax case under
section 7463.
Section 7463 generally allows disputes in small tax cases to
be decided in proceedings in which the normally applicable
procedural and evidentiary rules are relaxed. For example, Rule
174(b) provides: “Trials of small tax cases will be conducted as
informally as possible consistent with orderly procedure, and any
evidence deemed by the Court to have probative value shall be
admissible.” Tax Court decisions in small tax cases cannot be
appealed. Sec. 7463(b).
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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Last modified: May 25, 2011