Opinion
23064-22
01-23-2023
ALFRED BECERRA, SR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 18, 2023, petitioner electronically filed a set of documents, designating the filing as a "First Amended Answer." Upon review thereof, the Court notes that the filing appears to consist of documents 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 IRS) to review and consider certain documents, such as the aforementioned documents filed with the Court on January 18, 2023, petitioner may provide any such documents directly to the attorneys representing respondent in this matter. The names of those attorneys and their contact information are included in respondent's Answer filed on December 15, 2022.
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 Amended Answer is recharacterized as petitioner's Exhibit(s).