Opinion
4435-24S
06-05-2024
MOHAMMADREZA JANATKHAH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On June 4, 2024, petitioner electronically filed two documents titled First Supplement to Petition (Doc. Index Nos. 8 and 9). Those filings appear to be documents in the nature of evidence. The Tax Court is separate and independent from the Internal Revenue Service. Petitioner is advised that the just-referenced documents have not been received into evidence by the Court at this time and, 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.
Petitioner is further advised that in the future, unless otherwise directed, if petitioner seeks to have the Commissioner (respondent) review and consider documents in an effort to reach a settlement before any trial in this case, petitioner should provide those documents directly to respondent's counsel rather than filing them with the Court. The contact information for respondent's counsel was included in respondent's Answer, which was filed on or before May 8, 2024. For more information, petitioner may consult "Guidance for Taxpayers" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.
Upon due consideration, it is
ORDERED that petitioner's above-referenced First Supplements to Petition are each recharacterized as an Exhibit. It is further
ORDERED that the Court shall take no action on petitioner's above-referenced filings at this time.