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The unpaid tax in this case is more than three times the
$50,000 limit provided in section 7463(f)(2). We have therefore
removed the small tax case designation and discontinued the
proceedings under section 7463. We will take appropriate action
so that proceedings in this case will be conducted in conformity
with procedures applicable to section 6330 collection cases that
are not designated as small tax cases under section 7463.
An appropriate order will
be issued.
10(...continued)
7436(c)(3) provides: “Rules similar to the rules of the last
sentence of subsection (a), and subsections (c), (d), and (e), of
section 7463 shall apply to proceedings conducted under this
subsection.”
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Last modified: May 25, 2011