Opinion
9229-23S
10-04-2023
BRIAN JEFFREY MARSHALL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
The Tax Court is separate and independent from the IRS. On October 2, 2023, petitioner electronically filed with the Court the following improperly titled documents: (1) Affidavit of Eva Marie Marshall in Support of Notice of Attachments in the Nature of Evidence (Docket Index No. 9); (2) Affidavit of Eva Mari Marshall in Support of Affidavit of Eva Marie Marshall in Support of Notice of Attachments in the Nature of Evidence (Docket Index No. 10); and (3) Administrative Record (Docket Index No. 11).
Petitioner is advised that the above-described documents appear to be documents in the nature of evidence. These documents have 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.
Upon due consideration, it is
ORDERED that petitioner's Affidavit of Eva Marie Marshall in Support of Notice of Attachments in the Nature of Evidence (Docket Index No. 9) and Affidavit of Eva Mari Marshall in Support of Affidavit of Eva Marie Marshall in Support of Notice of Attachments in the Nature of Evidence (Docket Index No. 10) are each recharacterized as an Exhibit. It is further
ORDERED that petitioner's Administrative Record is recharacterized as a Letter Dated October 2, 2023. It is further
ORDERED that, if petitioner seeks to have respondent review and consider documents in an effort to reach a settlement in this case prior to trial, petitioner 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 to the Petition, which was filed July 26, 2023. For more information, petitioner's attention is invited to "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov. It is further ORDERED that the Court will take no action on petitioner's above-referenced filings at this time.