Opinion
588-24
03-08-2024
PATRICK JAMES DOYLE & SOPHIE DOYLE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 4, 2024, petitioners filed a document titled "Statement advertising expenses". Petitioners' filing appears to be evidentiary in nature. Petitioners are advised that their filing has not been received into evidence by the Court at this time and, unless otherwise directed by the Court, the proper time to present documentary evidence for inclusion in the Court's record is at the trial of this matter. If petitioners seek to have respondent review and consider documents in an effort to reach a settlement in this case prior to trial, in the future petitioners shall provide those documents directly to respondent's counsel, rather than filing them with the Court. The contact information for respondent's counsel is included in respondent's Answer, which was filed February 22, 2024.
For more information, petitioners' attention is invited to "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.
Upon due consideration and for cause, it is
ORDERED that petitioners' filing titled "Statement advertising expenses" is recharacterized as petitioners' Exhibit(s). It is further
ORDERED that the Court will take no action on petitioners' Exhibit(s) at this time.