Opinion
309-22S
04-07-2022
ADAM H. HERBERT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Maurice B. Foley Chief Judge
On January 18, 2022, petitioner filed a document improperly titled "Brief in Support of Petition" (Doc. Index No. 5) and four documents improperly titled "Brief in Support of Brief in Support of Petition" (Doc. Index Nos. 6, 7, 8, and 9). Those documents appear to consist mainly 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 is included in respondent's answer to the petition, filed February 28, 2022. 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 the petitioner's above-referenced documents, filed January 18, 2022, at Doc. Index Nos. 5, 6, 7, 8, and 9, are each recharacterized as a Report.