Opinion
19973-18 19975-18 19978-18 20001-18
11-22-2021
Michael Johnson & Cynthia Johnson, et al., Petitioners v. Commissioner of Internal Revenue, Respondent
ORDER
Joseph W. Nega Judge
These consolidated cases were remotely tried at the Special Session at the Court that commenced on March 1 and ended on March 9, 2021. Counsel for both parties appeared and were heard and these consolidated cases were submitted to the undersigned on March 9, 2021.
By Court Order issued August 31, 2021, the parties were directed on or before November 10, 2021, to file their respective simultaneous opening briefs with the Court.
On November 10, 2021, petitioners a Simultaneous Opening Brief which included a document entitled, "Description And Technical Explanation Of The Conference Agreement Of H.R. 6, Title XIII, The "Energy Tax Incentives Act Of 2005" as an Exhibit A. Petitioners' Simultaneous Opening Brief filed November 10, 2020, is an improper document to file with this Court and does not conform to the requirements of Rule 151, Tax Court Rules of Practice and Procedure.
The Court will again direct petitioners to re-file petitioners' Simultaneous Opening Brief to the requirements of Rule 151, Tax Court Rules of Practice and Procedure. All of these Rules are available on the U.S. Tax Court's website at www.ustaxcourt.gov.
Upon due consideration and for cause, it is
ORDERED that petitioners' Simultaneous Opening Brief, filed November 10, 2021, is stricken from the Court's record. It is further
ORDERED that the time within which petitioners shall file petitioners' Simultaneous Opening Brief is extended to and including December 3, 2021.