Opinion
11216-21
04-21-2023
TANYARD FARMS, LLC, TANYARD INVESTORS, LLC, TAX MATTERS PARTNER Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris Judge
On April 18, 2023, docket entry 35, the parties filed with the Court a Joint Motion for Leave to File First Amended Exhibit(s) and lodged concurrently at docket entry 36, First Amended Exhibit(s) to First Stipulation of Facts.
The parties' Joint Motion indicates that the parties request the Court strike the Exhibits to the First Stipulation of Facts, filed on March 1, 2023, docket entry 32, and refile corrected Exhibits.
On March 1, 2023, the parties filed the First Stipulation of Facts, with accompanying Exhibits (1-J through 22-J), at docket entries 31 and 32. Only after the Exhibits were filed, the parties realized that the document stipulated as Exhibit 12-J was mislabeled as Exhibit 11-J. The parties also made additional redactions per Tax Court Rule 27 to Exhibits 17-J, 18-J, and 21-J. The parties agree that the Exhibits identified in the First Stipulation of Facts are correct but for the corrections to the label on Exhibit 12-J and to redacted sensitive private information in Exhibits 17-J, 18-J, and 21-J. Accordingly, the parties request leave of Court to strike the Exhibits filed March 1, 2023, docket entry 32 and to refile Exhibits 1-J through 22-J with the correct labels ("Corrected Exhibits").
After due consideration, and for cause, it is
ORDERED that the parties' Exhibit(s) to First Stipulation of Facts, filed March 1, 2023, docket entry 32, is stricken from the Court's record in this case. It is further
ORDERED that the parties' Joint Motion for Leave to File First Amended Exhibit(s), filed April 18, 2023, docket entry 35, is granted, in that the Clerk of the Court is directed to file the parties' First Amended Exhibit(s) to First Stipulation of Facts lodged April 18, 2023, docket entry 36, as of the date of this Order.