Opinion
10767-24S
07-16-2024
JODY FERGUSON & RICHARD FERGUSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On July 2, 2024, petitioners made two electronic filings improperly designated as an "Answer" and as a "Declaration of Michael Hicks in Support of Answer." These filings consist of documents in the nature of evidence. We therefore inform petitioners that those documents have not been received into evidence by the Court, 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.
If, in an effort to settle this matter before trial, petitioners would like respondent (i.e., the Internal Revenue Service) to review and consider certain documents, petitioners may provide those documents directly to the attorney who will be representing respondent in this matter. The contact information for that attorney will be included in the answer that respondent files to the Petition. Respondent has 60 days from the date of service of the Petition within which to file the answer.
For further information, petitioners may consult "Guidance for Petitioners" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.
Upon due consideration and for cause, it is
ORDERED that petitioners' filings at Docket Index Nos. 6 and 7 are recharacterized as petitioners' Exhibit(s). It is further ORDERED that, at this time, no further action will be taken with respect to petitioners' Exhibit(s).