Opinion
1601-23S
05-05-2023
GODFREY WABOMBA NALYANYA & CLEMENTINE WAVINYA WABOMBA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On May 2, 2023, petitioners electronically filed a set of documents with the Court, designating the filing as a "First Supplement to Third Supplement to Letter by Petitioner." Upon review of the filing, we note that it appears to consist of documents in the nature of evidence. We therefore inform petitioners that neither those documents, nor the previous documents that they electronically filed with the Court (see Docket Entry Nos. 6 through 9), have been received into evidence by the Court. Additionally, we inform petitioners 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, petitioners would like respondent (i.e., the Internal Revenue Service) to review and consider certain documents, such as those that petitioners have filed with the Court, petitioners may provide those documents directly to the attorney who is representing respondent in this matter. The contact information for that attorney is included in the Answer, filed April 10, 2023.
For further information, petitioners may consult "Guidance for Petitioners" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.
In consideration of the foregoing, it is
ORDERED that the filing appearing at Docket Entry No. 12 is recharacterized as petitioners' "Exhibit(s)."