Opinion
4818-24
05-23-2024
TEDI DOMOWICZ DUREE & TOBY LEE DUREE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On May 21, 2024, petitioners filed a document titled "Memorandum," which appears to constitute a First Amendment to Petition. Attached thereto are 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 petitioners 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 was included in respondent's Answer, which was filed on May 17, 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 petitioners' above-referenced Memorandum is recharacterized as petitioners' First Amendment to Petition.