Opinion
1040-23S
02-13-2023
RAVI KANTH AKKINEPALLI & HARATHI RAO RAYARAO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On February 10, 2023, petitioners filed electronically in the above-docketed matter two documents under the designation "Exhibit(s)". The first consists of a copy of the notice of deficiency for 2020 underlying this proceeding and, as such, is properly in the nature of an First Amendment to Petition. The second, however, consists of brokerage account materials and, as such, appears to be potentially evidentiary in nature, submitted by petitioners in support of their position herein.
The Court would therefore take this opportunity to advise petitioners that 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 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 document filed February 10, 2023, at Docket Entry #5 shall be recharacterized as a First Amendment to Petition. It is further
ORDERED that the document filed February 10, 2023, at Docket Entry #6 is hereby deemed stricken from the Court's record in this case.