Opinion
5421-24
06-03-2024
DONNA S. DAVIS & DANIEL A. DAVIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On June 2, 2024, petitioners electronically filed (1) a First Amended Petition at Docket Index No. 8 and (2) a set of documents designated as a "Memorandum in Support of First Amended Petition" at Docket Index No. 9. The Court notes that the latter filing appears to include documents in the nature of evidence. Accordingly, we inform 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.
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, petitioners 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 First Amended Petition. Respondent has 60 days from the date of service of the First Amended Petition within which to file the answer.
For further information, petitioners may consult "Guidance for Taxpayers" 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' filing at Docket Index No. 9 is recharacterized as petitioners' Exhibit(s).