26 USC App Rule 173: Discontinuance of Proceedings
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26 USC App Rule 173: Discontinuance of Proceedings
From Title 26-AppendixINTERIM AMENDMENTS
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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 $50,000 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.

Effective Date of Amendment

Amendment effective with respect to proceedings commenced after July 22, 1998.

TITLE XVIII.-SPECIAL TRIAL JUDGES