Opinion
26464-22S
04-13-2023
MICHAEL V. JOHNSON & CAROLE W. JOHNSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 11, 2023, petitioners electronically filed a set of documents at Docket Index No. 7, designating the filing as "Proposed Trial Exhibits." These documents appear to be in the nature of evidence. We therefore advise petitioners that the 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. Generally, evidentiary materials are not filed with the Court.
If, in an effort to settle this matter before trial, petitioners would like respondent (i.e., the Internal Revenue Service) to review and consider certain documents, such as those that petitioners have filed with the Court, petitioners may provide those documents directly to the attorneys representing respondent in this matter. The names of those attorneys and their contact information are included in respondent's Answer, filed February 2, 2023.
For further information, petitioners may consult "Guidance for Petitioners" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.
Upon due consideration and for cause, it is
ORDERED that petitioners' filing at Docket Index No. 7 is recharacterized as petitioners' Report.