Opinion
24304-21S
02-22-2023
JOHN J. EVAN & CARISSA R. CLARK, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Peter J. Panuthos Special Trial Judge
This matter was submitted to the Court after trial on September 26, 2022. At the commencement of trial, the parties filed a Stipulation of Facts containing one exhibit (Exhibit 1-J). On September 12, 2022, respondent filed with the Court, Proposed Trial Exhibits, with eight attachments marked Exhibits 1000-R, 1001-R, 1002-R, 1003-R, 1004-R, 1005-R, 1006-R, 1007-R, and 1008-R. The exhibits include a copy of a "graphic print of petitioners' e-filed tax return for the 2018 tax year", a copy of the notice of deficiency, and transcripts of petitioners' account for tax years 2007, 2009, 2010, 2011, 2012, 2013, 2014, 2015 and 2016.
A review of the record reflects that the aforementioned documents were not offered into evidence by the parties, nor entered into evidence by the Court. However, reference was made to these documents during the trial. The Court concludes that it is essential to include these documents into the record in order that the Court have as complete a record as possible to fully adjudicate this matter.
The Court will re-open the record and admit into evidence Exhibits 1000-R, 1001-R, 1002-R, 1003-R, 1004-R, 1005-R, 1006-R, 1007-R, and 1008-R. Upon admission of the documents into evidence the Court will close the record and the case will be considered submitted.
Premises considered, it is hereby
ORDERED that the record in this matter is opened for the purpose of admission of further exhibits. It is further
ORDERED that Exhibits 1000-R, 1001-R, 1002-R, 1003-R, 1004-R, 1005-R, 1006-R, 1007-R, and 1008-R, attached to respondent's Proposed Trial Exhibits, filed September 12, 2022, are hereby admitted into evidence. It is further
ORDERED that the record in this case is closed and this matter is deemed submitted.