Opinion
19775-23
03-13-2024
ELIAS DAMIEN WILLIAMS ESTES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On March 9, 2024, petitioner filed a document improperly titled as an Administrative Record, which appears to consist of a document in the nature of evidence.
Petitioner is advised that the above-referenced document has 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.
Petitioner is further advised that, unless otherwise directed, in the future if petitioner seeks to have the Commissioner (respondent) review and consider documents in an effort to reach a settlement before any trial in this case, petitioner should provide those documents directly to respondent's counsel. The contact information for respondent's counsel included included in respondent's Answer, which was filed on March 1, 2024. For more information, petitioner's attention is invited to "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.
Upon due consideration, it is
ORDERED that the above-referenced Administrative Record is recharacterized as an Exhibit. It is further
ORDERED that the Court shall take no action on petitioner's above-referenced filing at this time.