Opinion
14269-24S
09-05-2024
IAN MICHAEL HAFNER & CHRISTINE-CLAYRE FLASHMAN HAFNER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On September 5, 2024, petitioners filed a Declaration of Ian Hafner in Support of Petition. Documents in the nature of evidence are attached to that filing. Petitioners are advised that the just-referenced documents have not been received into evidence by the Court at this time 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. Petitioners are further advised that in the future, unless otherwise directed, if petitioners seek to have the Commissioner (respondent) review and consider documents in an effort to reach a settlement before any trial in this case, petitioners should provide those documents directly to respondent's counsel. The contact information for respondent's counsel will be included in respondent's Answer, which is due to be filed on or before November 3, 2024. For more information, petitioners may consult "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.
Upon due consideration, it is
ORDERED that petitioners' Declaration of Ian Hafner in Support of Petition is recharacterized as Proposed Trial Exhibits.