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decide whether the Court has the authority to decide this case
pursuant to the small tax case provisions of section 7463.
Section 7463(a) allows the small tax case procedures to be
used for cases
filed with the Tax Court for a redetermination of a
deficiency where neither the amount of the deficiency
placed in dispute, nor the amount of any claimed
overpayment, exceeds--
(1) $50,000 for any one taxable year, in
the case of the taxes imposed by subtitle A,
(2) $50,000, in the case of the tax
imposed by chapter 11,
(3) $50,000 for any one calendar year, in
the case of the tax imposed by chapter 12, or
(4) $50,000 for any 1 taxable period (or,
if there is no taxable period, taxable event)
in the case of any tax imposed by subtitle D
which is described in section 6212(a)
(relating to a notice of deficiency) * * *
[Emphasis added.]
Prior to December 21, 2000, there was no statutory authority for
utilizing the small tax case procedures for section 6330
collection cases. However, effective December 21, 2000, the
Community Renewal Tax Relief Act of 2000, Pub. L. 106-554, sec.
313(b)(1), 114 Stat. 2763A-642, added section 7463(f), which
provides:
SEC. 7463(f). Additional Cases in Which
Proceedings May Be Conducted Under This Section.--At
the option of the taxpayer concurred in by the Tax
Court or a division thereof before the hearing of the
case, proceedings may be conducted under this section
(in the same manner as a case described in subsection
(a)) in the case of--
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Last modified: May 25, 2011