Opinion
12271-20 12274-20
04-05-2023
JACKSON STONE SOUTH, LLC, JACKSON SOUTH INVESTMENTS, LLC, TAX MATTERS PARTNER, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall Judge
These consolidated cases were called for trial at the Special Trial Session of the Court which commenced on March 13, 2023, in Washington, D.C.
On March 10, 2023, respondent filed with the Court a Sixth Stipulation of Facts at docket No. 12271-20 (docket entry 283) and at docket No.12274-20 (docket entry 291) in which it proposed to have attached two exhibits, 1279-R and 1280-R. Additionally, on March 10, 2023, respondent filed with the Court a separate filing at docket No. 12271-20 (docket entry 284) and at docket No. 12274-20 (docket entry 292) claiming to be the exhibits that should have been attached to the Sixth Stipulation of Facts in both cases were not labeled with exhibit numbers, 1279-R and 1280-R. To remedy this error, on March 13, 2023, respondent filed with the Court at docket No. 12271-20 (docket entry 316) and at docket No. 12274-20 (docket entry 328) the accurately labeled exhibits, 1279-R and 1280-R. Therefore, the Court strikes the above-referenced docket entries 284 and 292 and retains the accurately labeled exhibits on the record as docket entries 316 and 328 to accompany the Sixth Stipulation of Facts in each case.
Upon due consideration and for cause, it is
ORDERED that respondent's Exhibit filed on March 10, 2023, at docket No. 12271-20 (docket entry 284) and at docket No. 12274-20 (docket entry 292), is hereby stricken from the record.