- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011