Opinion
18394-23S
02-16-2024
ORDER
Kathleen Kerrigan Chief Judge
On February 1, 2024, respondent filed a Status Report, attaching thereto a copy of the notice of deficiency upon which this case is based. On February 15, 2024, petitioner filed a Reply to Status Report, attaching thereto a miscellany of documents. Upon review, the Court notes that some of those documents appear to be in the nature of evidence. Petitioner is therefore informed 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.
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 has filed with the Court, petitioner may provide those documents directly to the attorneys representing respondent in this matter. Petitioner may find the contact information for those attorneys in respondent's Answer to Amended Petition, filed January 29, 2024.
For further information, petitioner may consult "Guidance for Petitioners" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.
In consideration of the foregoing, it is
ORDERED that at this time the Court will take no further action in response to petitioner's Reply to Status Report.