Opinion
13300-22S 7232-23S 14695-23S 11844-24S
09-25-2024
PETER J. JANANGELO, JR. & MARY ANN JANANGELO, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Jennifer E. Siegel, Special Trial Judge
On September 23, 2024, petitioners filed a Motion for Continuance and a memorandum in support thereof. The motion consists, without explanation, of work-related emails and a page from an amended complaint filed in the United States Court of Federal Claims concerning someone other than the Janangelos. The document styled as a memorandum is a duplicate of the motion.
Premises considered, it is
ORDERED that petitioners' Motion for Continuance is denied. It is further
ORDERED that the Motion for Continuance is sealed and shall not be open for inspection by any person or entity not a party to this case, except by an Order of the Court. It is further
ORDERED that the Memorandum in Support of Motion for Continuance is deemed stricken from the record of this case and shall not be made viewable by any person or entity not a party to this case.