Opinion
36764-21
06-23-2022
WARREN A. HARRIS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
By Notice of Deficiency dated September 13, 2021, respondent determined a deficiency and accuracy-related penalty in petitioner's federal income tax for the 2019 taxable year. On December 13, 2021, petitioner filed a timely Petition for redetermination with respect to that Notice. On March 16, 2022, respondent filed an Answer. Thereafter, on March 28, 2022, petitioner electronically filed a document that he designated as a "Redacted Petition." However, upon further review, the Court finds that the aforementioned filing is more akin to a first amendment to petition, and we will accordingly recharacterize it as such.
The Court notes that petitioner's subsequent electronic filings in this case generally contain documents that are either duplicative or in the nature of evidence. We therefore advise petitioner that those documents have not been received into evidence by the Court 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. Generally, evidentiary materials are not filed with the Court.
If, in an effort to settle this matter before trial, petitioner would like respondent (i.e., the Internal Revenue Service) to review and consider certain documents, such as those that petitioner has filed with the Court, he is advised to provide those documents directly to the attorneys representing respondent in this matter. The contact information for those attorneys is included in respondent's Answer, filed March 16, 2022.
For more information, petitioner is directed to consult "Guidance for Petitioners" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.
The foregoing considered, it is
ORDERED that petitioner's Redacted Petition is recharacterized as petitioner's First Amendment to Petition. It is further
ORDERED that petitioner's Response to Answer, filed March 28, 2022, at Docket Index No. 6, is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that petitioner's Declaration of Warren Harris in Support of Response to Answer, filed March 28, 2022, at Docket Index No. 7, is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that petitioner's Declaration of Warren Harris in Support of Response to Answer, filed March 28, 2022, at Docket Index No. 8, is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that petitioner's Declaration of Warren Harris in Support of Response to Answer, filed March 28, 2022, at Docket Index No. 9, is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that petitioner's Declaration of Warren Harris in Support of Response to Answer, filed March 28, 2022, at Docket Index No. 10, is hereby deemed stricken from the Court's record in this case. It is further
ORDERED that petitioner's Second Supplement to Response to Answer, filed May 20, 2022, at Docket Index No. 11, is hereby deemed stricken from the Court's record in this case.