Opinion
5055-23S
04-17-2023
STANLEY M. BERRY & DONNA K. BERRY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On April 10, 2023, petitioners electronically filed the following improperly titled documents: (1) Answer (Doc. 5); (2) Brief in Support of Answer (Doc. 6); (3) Brief in Support of Answer (Doc. 7); (4) Brief in Support of Answer (Doc. 8); and (5) Brief in Support of Answer (Doc. 9)
Upon due consideration, it is ORDERED that petitioners' Answer is recharacterized as a Report. It is further
ORDERED that each of the documents titled Brief in Support of Answer is recharacterized as an Exhibit to Report. It is further
ORDERED that petitioners are advised that the above-described exhibits appear to be documents in the nature of evidence. These documents have not been received into evidence by the Court at this time and, unless otherwise directed by the Court, the proper time to present documentary evidence for inclusion in the Court's record is at the trial of this matter. In the future, if petitioners seek to have respondent review and consider documents in an effort to reach a settlement in this case prior to trial, petitioners shall provide those documents directly to respondent's counsel, rather than filing them with the Court. The contact information for respondent's counsel will be included in respondent's Answer to the petition, which is due to be filed on or before June 6, 2023. For more information, petitioners' attention is invited to "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.