Opinion
6494-23S
05-03-2023
LINDA S. LANGR, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On May 1, 2023, petitioner electronically filed five separate sets of documents with the Court, designating each filing as a "Memorandum." Upon review thereof, the Court notes that some of the filings appear to consist of documents in the nature of evidence. We therefore advise petitioner that those 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, petitioner would like respondent (i.e., the Internal Revenue Service) to review and consider certain documents, such as those that petitioner has filed with the Court, petitioner may provide those documents directly to the attorney who will be representing respondent in this matter. 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 further information, petitioner may consult "Guidance for Petitioners" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.
In consideration of the foregoing, it is
ORDERED that each of the filings appearing at Docket Index Nos. 6 through 10 is recharacterized as petitioner's "Exhibit(s) to Petition."