Opinion
744-23
02-02-2023
ALI Y. ATAMAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On February 1, 2023, petitioner electronically filed a set of documents under the designation, "First Supplement to Petition." Upon review of that filing, the Court notes that the documents appear to be in the nature of evidence. We therefore advise petitioner that those documents have 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. In general, evidentiary materials are not filed with the Court.
If, in an effort to settle this matter before trial, petitioner would like respondent (i.e., the Internal Revenue Service) to review and consider certain documents, such as those that petitioner filed with the Court on February 1, 2023, petitioner may provide any such documents directly to the attorneys who will be representing respondent in this matter. The names of those attorneys and their contact information will be included in the answer that respondent files to the Petition.
For further information, petitioner may consult "Guidance for Petitioners" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.
Upon due consideration and for cause, it is
ORDERED that petitioner's First Supplement to Petition is recharacterized as petitioner's Exhibit(s).