Internal Revenue Code:Rule 173. Discontinuance of Proceedings

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Location in Internal Revenue Code

     TITLE 26 - INTERNAL REVENUE CODE
      TITLE 26 - APPENDIX
       TITLE XVII. - SMALL TAX CASES
     

Statute

    Rule 173. Discontinuance of Proceedings
 
      After the commencement of a trial of a small tax case, but before
    the decision in the case becomes final, the Court may order that
    the proceedings be discontinued under Code Section 7463, and that
    the case be tried under the Rules of Practice other than the Small
    Tax Case Rules, but such order will be issued only if (1) there are
    reasonable grounds for believing that the amount of the deficiency,
    or the claimed overpayment, in dispute will exceed $10,000 and (2)
    the Court finds that justice requires the discontinuance of the
    proceedings under Code Section 7463, taking into consideration the
    convenience and expenses for both parties that would result from
    the order.
                             INTERIM AMENDMENT
        For interim amendment of this Rule, see provisions set out
      after the Appendices to the Rules.