Opinion
34910-21S
01-10-2022
Robert G. Antonsen, Jr. & Karen M. Antonsen Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge.
On January 3, 2022, petitioners filed electronically in the above-docketed matter a document under the designation "Motion for Summary Judgment". However, review of the record shows that the so-called consists of voluminous copies of communications with the Internal Revenue Service (IRS) and of financial information. As such, the filed document is not in the nature of a Motion for Summary Judgment; instead, it appears to be potentially evidentiary in nature, submitted by petitioners in support of their position herein.
The Court would therefore take this opportunity to stress that evidentiary materials generally are not filed with the Court; rather, they should be exchanged with counsel for the IRS as part of the pretrial process (before trial) and then introduced at trial if the case has not been settled prior thereto. Because the IRS is separate from this Court, petitioners are accordingly advised to contact IRS counsel directly regarding such matters, once an attorney from the IRS files an answer and/or enters an appearance in this case.
Upon due consideration, it is
ORDERED that the document filed January 3, 2022, as a Motion for Summary Judgment is hereby deemed stricken from the Court's record in this case.