Opinion
25826-21
12-29-2023
MICHAEL CHARLES ESPINOZA & SANDRA YANIRA DELGADO-ESPINOZA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On December 20, 2023, petitioners electronically filed five documents in this case (Docket Index Nos. 29-33). On December 22, 2023, petitioners electronically filed seven more documents (Docket Index Nos. 39-40). On December 26, 2023, petitioners electronically filed four more documents (Docket Index Nos. 41-44). Many of these documents are evidentiary in nature; others consist of FedEx receipts for mailing the documents to respondent's counsel and accompanying certificates of service.
Petitioners are advised that the above-described documents have not been received into evidence by the Court at this time and, unless otherwise directed by the Court, the proper time to present documentary evidence for inclusion in the Court's record is at the trial of this matter. In the future, if petitioners seek to have respondent review and consider documents in an effort to reach a settlement in this case prior to trial, petitioners should provide those documents directly to respondent's counsel, rather than filing them with the Court. The contact information for respondent's counsel is included in respondent's Answer, which was filed on March 20, 2023. For more information, petitioners' attention is invited to "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.
Upon due consideration, and for cause, it is
ORDERED that petitioners' above-referenced documents filed at Docket Index Nos. 29, 30, 31, 32, 33, 35, 37, 38, 39, 42, and 43 are recharacterized as "Exhibit(s)."