Opinion
11431-23S
07-24-2023
NICHOLAS C. RUGGIERO & NICOLE M. RUGGIERO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On July 20, 2023, petitioners electronically filed two sets of documents, designating each filing as petitioners' "Exhibit(s)." These filings appear to consist of documents in the nature of evidence. Petitioners are therefore informed that the 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, 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 will be representing respondent in this matter. The contact information for that attorney will be included in the answer that respondent files to the Petition. (Respondent has 60 days from the date of service of the Petition within which to file the answer.)
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 Court will take no action with respect to petitioners' Exhibit(s), filed July 20, 2023, at Docket Index Nos. 6 and 7.