Opinion
8250-24
07-03-2024
SUSAN J. DELGRECO & ANTHONY A. DELGRECO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On June 18, 2024, petitioners filed a First Amendment to Petition. However, the Court notes that certain documents attached thereto appear to be documents in the nature of evidence.
The Tax Court is separate and independent from the Internal Revenue Service. Petitioners are advised that the above-referenced documents have not been received into evidence by the Court at this time and that, unless otherwise directed by the Court, the appropriate time to present documentary evidence for inclusion in the Court's record is at the trial of this matter.
Petitioners are further advised that in the future, unless otherwise directed, if petitioners seek to have the Commissioner (respondent) review and consider documents in an effort to reach a settlement before any trial in this case, petitioners should provide those documents directly to respondent's counsel. The contact information for respondent's counsel will be included in respondent's Answer, which is due to be filed 60 days from the date of service of petitioners' Petition. See Rule 36(a), Tax Court Rules of Practice and Procedure. For more information, petitioners may consult "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.
Upon due consideration, it is ORDERED that the Court shall take no action on petitioners' above-referenced filings at this time.