Opinion
406-23
06-30-2023
ORDER
Kathleen Kerrigan Chief Judge
On March 6, 2023, petitioners electronically filed a set of documents at Docket Index Nos. 6, 7, 8, and 9, designating the filings as "Exhibit(s)". On June 12, 2023, petitioners electronically filed another document at Docket Index No. 11, designating that filing as an "Affidavit of Melinda Lepoureau in Support of Petition".
The above-described filings appear to consist of documents in the nature of evidence. Petitioners are therefore informed 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 unless pursuant to a Standing Pretrial Order.
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 attorney representing respondent in this matter. Petitioners may find the contact information for that attorney in respondent's Answer, filed March 9, 2023.
For further information, petitioners 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 petitioners' "Affidavit of Melinda Lepoureau in Support of Petition" (Docket Index No. 11) is recharacterized as petitioners' "Exhibit(s)". It is further
ORDERED that the Court will take no action with respect to petitioners' above-referenced Exhibit(s).