Opinion
15205-24S
09-25-2024
ROBERT MILLER BRICE III & WEATHERLY ROGERS BRICE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On September 23, 2024, petitioners filed five documents, each titled Exhibit(s) (Docket Index Nos. 6, 7, 8, 9, and 10). Most of those filings appear to be documents in the nature of evidence. The Tax Court is separate and independent from the Internal Revenue Service. Petitioners are advised that the above-referenced documents have not been received into evidence by the Court at this time 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. Petitioners are further advised that in the future, unless otherwise directed, if they seek to have the Commissioner (respondent) review and consider documents in an effort to reach a settlement before any trial in this case, petitioners should provide those documents directly to respondent's counsel. The contact information for respondent's counsel will be included in respondent's Answer, which is due to be filed on or before December 18, 2024. For more information, petitioners may consult "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.
Upon due consideration, it is
ORDERED that the document filed at Docket Index No. 6 is recharacterized as a Letter from Petitioner Robert Miller Brice III. It is further
ORDERED that the documents filed at Docket Index Nos. 7, 8, 9, and 10 are each recharacterized as a Proposed Trial Exhibit.