Opinion
10709-24
07-22-2024
AARON DOUGLAS DEEM & LIU I-CHUN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On July 19, 2024, petitioners filed the following: (1) two documents improperly titled Brief in Support of Petition (Docket Index Nos. 7 and 8), and (2) three documents titled Exhibit(s) (Docket Index Nos. 9, 10, and 11). 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 August 30, 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 above-referenced Briefs in Support of Petition (Docket Index Nos. 7 and 8) are each recharacterized as an Exhibit. The Court shall take no action on petitioners' above-referenced filings at this time.