Opinion
9973-22S
05-09-2022
ZHEN HE & XUELING LOU, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley, Chief Judge
On May 7 and 8, 2022, petitioners filed electronically in the above-docketed matter a series of nine documents under the designations "Brief in Support of Petition" and "Memorandum in Support of Petition". However, review of the record shows that the so-called brief and memoranda consist in their entirety of mortgage-related statements and paperwork. As such, the filed documents are not in the nature of briefs or memoranda; instead, they appear to be potentially evidentiary in nature, submitted by petitioners in support of their position herein.
The Court would thus take this opportunity to stress that evidentiary materials generally are not filed with the Court at this juncture; rather, they should be exchanged with counsel for the Internal Revenue Service (IRS) as part of the pretrial 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 accordingly advised to contact IRS counsel directly regarding such matters.
Upon due consideration, it is
ORDERED that the nine documents filed May 7 and 8, 2022, at Docket Entries #6 through #14 are hereby deemed stricken from the Court's record in this case.