Opinion
4865-19W
07-14-2023
LAWRENCE W. DOYLE & JOHN F. MOYNIHAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
David Gustafson, Judge
On June 30, 2023, petitioners made a filing (Doc. 167) in compliance with our order (Doc. 165) and in support of their motion to supplement the administrative record (Doc. 164). On its cover sheet the filing is entitled "First Supplement to Motion to Supplement the Record", and on its first page it is entitled "Supplement to Petitioners' Third Motion to Supplement the Record". We think, however, that the motion to supplement is their second such motion (not their third), with the first one being Doc. 109. To promote the clarity of our docket record, it is therefore
ORDERED that the Clerk of the Court shall retitle Doc. 164 as "Second Motion to Supplement the Administrative Record" and shall retitle Doc. 167 as "Supplement to Petitioners' Second Motion to Supplement the Administrative Record". The record in this case is lengthy and complex, and if this order overlooks or misconstrues any of these filings, we invite the parties to suggest corrections.