Opinion
9973-22S
11-23-2022
ZHEN HE & XUELING LOU, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Eunkyong Choi Special Trial Judge.
On November 20, 2022, petitioners filed a set of documents that they designated as a Brief in Support of Petition. Upon review of that filing, the Court notes that certain documents therein appear to be in the nature of evidence. We therefore advise petitioners 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. Evidentiary materials generally are not filed with the Court before trial.
If, in an effort to settle this matter before trial, petitioner would like respondent (i.e., the Internal Revenue Service) to review and consider certain documents, such as those that they have filed with the Court, petitioners are strongly advised to provide those documents directly to the IRS attorney representing respondent in this matter. The contact information for that attorney is included in respondent's Answer, filed June 27, 2022, to the Petition.
For more information, petitioners are directed to consult "Guidance for Petitioners" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.
The foregoing considered, it is
ORDERED that petitioners' Brief in Support of Petition, filed November 20, 2022, is recharacterized as petitioner's Report