Opinion
21812-22
11-08-2023
KRISHAN K. GOSSAIN & KAVITA GOSSAIN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Richard T. Morrison, Judge.
On October 30, 2023, the Court received from petitioners documents titled: (1) Plaintiff's Stipulation of Facts and (2) Request for Material Participation and Recomputations.
On November 2, 2023, the Court received from petitioners a document titled "Request for Material Participation - Exhibits Supporting Prior Years Material Participation." .
The Court's October 30, 2023 Standing Pretrial Order requires the parties to file an agreed stipulation of facts, on or before November 13, 2023. The stipulation of facts must be executed (i.e., signed) by all parties. The October 30, 2023 filing is signed only by one of the petitioners. It is not signed by respondent or the other petitioner. It is therefore not a stipulation of facts, but some sort of proposed stipulation of fact. Proposed stipulations of fact ordinarily are not filed with the Court. This document will be stricken from the Court's record in this case.
Petitioners' October 30, 2023 Request for Material Participation and Recomputations attaches a document. Petitioners are reminded that the Court's October 30, 2023 Standing Pretrial Order requires the parties to file with the Court Unagreed Trial Exhibits (all documents they intend to present as evidence at the trial that are not stipulated) on or before November 20, 2023. The filing appears to contain views of petitioners regarding the case. These views would be more appropriately expressed in petitioners' pretrial memorandum, which was due November 6, 2013. This document will be stricken from the Court's record in this case.
Petitioners' November 2, 2023 Request for Material Participation - Exhibits Supporting Prior Years Material Participation appears to be similar in nature to petitioners' October 30, 2023 Request for Material Participation and Recomputations. This document will be stricken from the Court's record in this case.
Given the foregoing, it is
ORDERED that petitioners' October 30, 2023 Stipulation of Facts, petitioners' October 30, 2023 Request for Material Participation and Recomputations, and petitioners' November 2, 2023 Request for Material Participation - Exhibits Supporting Prior Years Material Participation, are stricken from the record in this case.