Opinion
18164-22S
08-22-2022
MIKE CICHY & LAUREN STACY BRUHN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On August 18, 2022, petitioners electronically filed two sets of documents-the first designated as a First Amendment to Petition, and the second designated as a Brief in Support of Petition. Review of the First Amendment to Petition shows that the filing consists of a partial copy of the Notice of Deficiency upon which this case is based.
However, review of the Brief in Support of Petition shows that it consists of documents in the nature of evidence. We therefore advise petitioners 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. Generally, evidentiary materials are not filed with the Court.
If, in an effort to settle this matter before trial, petitioners would like respondent (i.e., the Internal Revenue Service) to review and consider certain documents, such as those that petitioners have filed with the Court, petitioners may provide those documents directly to the attorney who enters an appearance on behalf of respondent in this matter. That attorney will be identified in the answer that respondent files to the Petition in this case. Respondent has 60 days from the date of service of the Petition within which to file his answer.
For further information, petitioners 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 petitioners' Brief in Support of Petition is deemed stricken from the Court's record in this case. 1