Opinion
1049-22
02-10-2022
ORDER
Maurice B. Foley Chief Judge.
On February 3, 2022, petitioner filed the petition to commence this case. On February 9, 2022, petitioner filed documents improperly titled First Supplemental Petition and Brief in Support of First Supplemental Petition. The February 9, 2022, filings appear to consist of documents in the nature of evidence. Petitioner is 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, petitioner wishes respondent to review and consider certain documents, petitioner is advised to provide those documents directly to respondent's counsel. The contact information for respondent's counsel will be included in respondent's answer to the petition, which is due 60 days after the petition was served on respondent. For more information, petitioner is directed to consult "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.
Upon due consideration, it is
ORDERED that petitioner's First Supplemental Petition is recharacterized as Exhibits to Petition. It is further
ORDERED that petitioner's Brief in Support of First Supplemental Petition is recharacterized as Exhibits to Petition.