Opinion
20545-21S
01-11-2022
Josephine Giles & Jason Lewis Giles Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On January 3, 2022, petitioners efiled two documents. One is titled Answer, which consists of a three-page document and a number of exhibits that petitioners apparently intend to be an attachment to their petition. The other is titled Memorandum in Support of Answer, consisting of a duplicate copy of the just-described three-page document.
The attachments to petitioners' filing referenced above appear to be documents in the nature of evidence. Petitioners are advised that these 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 prior to trial, petitioners wish respondent to review and consider certain documents, petitioners are advised to provide those documents directly to respondent's counsel. The contact information for respondent's counsel is included in respondent's answer to the petition, which was filed November 16, 2021. For more information, petitioners are directed to consult "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.
In view of the foregoing, it is
ORDERED that petitioners' above-referenced Answer is recharacterized as a Motion for Leave to File First Amendment to Petition Embodying First Amendment to Petition (motion for leave). It is further
ORDERED that petitioner's motion for leave is granted. It is further
ORDERED that, on or before March 5, 2022, respondent shall file an answer to petition, as amended. It is further
ORDERED that petitioners' Memorandum in Support of Answer is stricken from the Court's record in this case.