Opinion
18241-23
11-29-2023
SARA HUSSAIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On November 20, 2023, petitioner electronically filed the Petition to commence this case. The Petition seeks review of a notice of deficiency dated October 2, 2023, and issued to petitioner for the taxable year 2021. No copy of the notice is attached to the Petition.
Thereafter, on November 22, 2023, petitioner electronically filed an additional set of documents, which petitioner designated as a First Supplement to Petition. The filing includes a partial copy of the aforementioned notice of deficiency. However, the filing also includes documents in the nature of evidence. Petitioner is informed that those 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 before trial, petitioner would like respondent (i.e., the Internal Revenue Service) to review and consider certain documents, such as those that petitioner has filed with the Court, petitioner may provide those documents directly to the attorney who will be representing respondent in this matter. The contact information for that attorney will be included in the answer that respondent files to the Petition. (Respondent has 60 days from the date of service of the Petition within which to file the answer.)
For further information, petitioner may consult "Guidance for Petitioners" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.
In consideration of the foregoing, it is
ORDERED that petitioner's First Supplement to Petition is recharacterized as petitioner's First Amendment to Petition.