Opinion
12948-23S
09-13-2023
RUSSEL WHITFIELD & TRINE WHITFIELD, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On September 10, 2023, petitioners filed documents titled "Administrative Record" and "First Amended Administrative Record." These documents are, respectively, a duplicate of petitioners' amended Petition and a Statement of Taxpayer Identification Number.
On the same day Petitioners also filed a document titled "Exhibit(s)," which appears to be in the nature of evidence. Petitioners are advised that the document has 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. Evidentiary materials generally are not filed with the Court; rather, they should be exchanged with counsel for the Internal Revenue Service (IRS) as part of the process before trial and then introduced at trial if the case has not been settled prior thereto. Because the IRS is separate from this Court, petitioners are advised to contact IRS counsel directly regarding such matters.
Upon due consideration and for cause, it is
ORDERED that petitioners' filing titled "Administrative Record" (Docket Index No. 7) is hereby deemed stricken. It is further
ORDERED that petitioners' filing titled "First Amended Administrative Record" (Docket Index No. 9) shall be recharacterized as petitioners' Statement of Taxpayer Identification Number and shall remain under seal. It is further
ORDERED that petitioners' filing titled "Exhibit(s)" (Docket Index No. 10) is hereby recharacterized as petitioners' Report.