Opinion
549-23
03-22-2023
MELANIE CHRISTINE TILLEY, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On January 23, 2023, petitioner filed the petition in this case, indicating therein that she seeks review of a notice of deficiency issued to her for "2022/2023". The notice of deficiency attached to the petition, however, was issued with respect to petitioner's 2021 tax year.
On March 21, 2023, respondent filed an Answer to the petition. On March 21, 2023, petitioner electronically filed the following improperly titled documents: (1) Administrative Record (Doc. 8), and (2) Brief in Support of Administrative Record (Doc. 9).
Upon due consideration, it is ORDERED that each of the above-described documents is recharacterized as an Exhibit. It is further
ORDERED that petitioner is advised that her above-described documents filed March 21, 2023, 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 is at the trial of this matter. In the future, 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, filed March 21, 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, on or before April 19, 2023, respondent shall file an appropriate jurisdictional motion with respect to petitioner's 2022 and 2023 tax years.