Opinion
8798-24S
06-05-2024
BLAIR G. JONES & LISA M. LEMAY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On May 31, 2024, petitioners filed the following improperly titled documents: (1) Administrative Record (Doc. Index No. 7); (2) First Supplemental Administrative Record (Doc. Index No. 8); (3) First Supplement to Administrative Record (Doc. Index No. 9); and (4) First Supplement to Administrative Record (Doc. Index No. 10).
The Tax Court is separate and independent from the Internal Revenue Service. Petitioners are advised that the above-referenced documents have not been received into evidence by the Court at this time 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.
Petitioners are further advised that in the future, unless otherwise directed, if they seek to have the Commissioner (respondent) review and consider documents in an effort to reach a settlement before any trial in this case, they should provide those documents directly to respondent's counsel. The contact information for that attorney will be included in the answer that respondent files to the Petition. Respondent has 60 days from the date of service of the Petition within which to file the answer. For more information, petitioners may consult "Guidance for Taxpayers" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.
Upon due consideration, it is
ORDERED that petitioners' above-referenced Administrative Record (Doc. Index No. 7), First Supplemental Administrative Record (Doc. Index No. 8), First Supplement to Administrative Record (Doc. Index No. 9), and First Supplement to Administrative Record (Doc. Index No. 10) are each recharacterized as an Exhibit. It is further
ORDERED that the Court shall take no action on petitioners' above-referenced filings at this time.