Opinion
7153-22S
09-21-2023
KATHRYN L. GARRISON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden, Special Trial Judge.
This case is calendared for trial at the October 23, 2023, Fresno, California, Trial Session of the Court.
On September 8, 2023, petitioner filed electronically in the above-docketed matter a series of 8 documents. However, review of the record shows that all are improperly titled, and the majority appear to be potentially evidentiary in nature, submitted by petitioner in support of her position herein. Because this case has been set for trial the Court on its own will recharacterize the filings as petitioner's Proposed Trial Exhibit(s) 500-P, 501-P, 502-P, 503-P, 504-P, 505-P, 506-P, and 507-P.
Rule 27(a), Tax Court Rules of Practice and Procedure, generally provides that in an electronic or paper filing with the Court, a party or nonparty making the filing should refrain from including or should take appropriate steps to redact certain specified information, such as taxpayer identification numbers and financial account numbers. Due to the unredacted personal identifying information appearing in the Proposed Trial Exhibit(s) 506-P and 507-P (Index #30 and #31), the Court will take steps to seal petitioner's Proposed Trial Exhibit(s) 506-P and 507-P (Index #30 and #31) to protect her information. Upon due consideration, it is
ORDERED that the document titled Exhibit(s) (Index #24), filed September 8, 2023, shall be recharacterized as Proposed Trial Exhibit(s) 500-P. It is further
ORDERED that the document titled Exhibit(s) (Index #25), filed September 8, 2023, shall be recharacterized as Proposed Trial Exhibit(s) 501-P. It is further
ORDERED that the Unsworn Declaration of Kathryn Garrison (Culotta) under Penalty of Perjury in Support of Exhibit(s) (Index #26), filed September 8, 2023, shall be recharacterized as Proposed Trial Exhibit(s) 502-P. It is further
ORDERED that the Unsworn Declaration of Kathryn Garrison (Culotta) under Penalty of Perjury in Support of Exhibit(s) (Index #27), filed September 8, 2023, shall be recharacterized as Proposed Trial Exhibit(s) 503-P. It is further
ORDERED that the Unsworn Declaration of Kathryn Garrison (Culotta) under Penalty of Perjury in Support of Exhibit(s) (Index #28), filed September 8, 2023, shall be recharacterized as Proposed Trial Exhibit(s) 504-P. It is further
ORDERED that the Unsworn Declaration of Kathryn Garrison (Culotta) under Penalty of Perjury in Support of Exhibit(s) (Index #29), filed September 8, 2023, shall be recharacterized as Proposed Trial Exhibit(s) 505-P. It is further
ORDERED that the Unsworn Declaration of Kathryn Garrison (Culotta) under Penalty of Perjury in Support of Exhibit(s) (Index #30), filed September 8, 2023, shall be recharacterized as Proposed Trial Exhibit(s) 506-P. It is further
ORDERED that the document titled Exhibit(s) (Index #31), filed September 8, 2023, shall be recharacterized as Proposed Trial Exhibit(s) 507-P. It is further
ORDERED that on the Court's own motion the unredacted Proposed Trial Exhibit(s) 506-P and 507-P (Index #30 and #31), filed on September 8, 2023, are sealed to public view.