Opinion
12336-23S
12-29-2023
LISA GARNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On December 28, 2023, petitioner filed a document improperly titled "Brief in Support of Answer." Both this document and petitioner's document titled "Exhibit(s)," also filed on December 28, 2023, appear to be evidentiary in nature. Petitioner is advised that these 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.
Upon due consideration, it is
ORDERED that petitioner's document titled "Brief in Support of Answer," filed December 28, 2023, at Docket Index No. 6, is recharacterized as petitioner's "Exhibit(s)." If petitioner seeks to have respondent review and consider documents in an effort to reach a settlement in this case prior to trial, in the future, petitioner shall 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 September 25, 2023. For more information, petitioner's attention is invited to "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.