Opinion
6051-24
04-26-2024
ORDER
Kathleen Kerrigan Chief Judge
On April 19, 2024, the Court received and filed petitioner's Letter dated April 15, 2024. This filing appears to consist of documents 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 the documents that petitioner has filed with the Court, petitioner may provide those documents directly to the attorney who will be representing respondent in this matter. The contact information for that attorney will be included in the answer that respondent files to the Petition. (Respondent has 60 days from the date of service of the Petition within which to file the answer.) 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 above-referenced Letter, filed on April 19, 2024, is recharacterized as petitioner's Exhibit(s). It is further
ORDERED that at this time the Court will take no further action with respect to petitioner's Exhibit(s).