RULE 170. GENERAL2
- TThe Rules of this Title XVII, referred to herein as the
"Small Tax Case Rules", set forth the special provisions
which are to be applied to small tax cases. The term "small
tax case" means a case in which the amount in dispute is
$50,000 or less (within the meaning of the Internal Revenue
Code) and the Court has concurred in the petitioner?s election.
See Code secs. 7436(c) and 7463. Except as otherwise
provided in these Small Tax Case Rules, the other Rules of
practice of the Court are applicable to such cases.
1 Title XVII sets forth the procedures to be applied in small tax cases,
which can now include proceedings under Code section 7436(c). Code section
7436(c) was added by section 1454(a) of the Taxpayer Relief Act of
1997, Pub. L. 105?34, 111 Stat. 1055, and provides for the applicability of
the small tax case procedures in certain actions for redetermination of employment
status, effective on August 5, 1997. Additionally, the maximum
amount in dispute in a case eligible for the small tax case procedures was
increased from $10,000 to $50,000 by section 3103(a) and (b)(1) of the Internal
Revenue Service Restructuring and Reform Act of 1998, Pub. L.
105?206, 112 Stat. 731, effective with respect to proceedings commenced
after July 22, 1998.
2 The amendments of Rule 170 generally are effective as of June 30,
2003; except that the amendment relating to the amount in dispute
($50,000 or less) is effective with respect to proceedings commenced after
July 22, 1998; and the amendment relating to Code section 7436(c) is effective
with respect to proceedings commenced on or after August 5, 1997.
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