Opinion
272-18
08-21-2024
LONTRAC ENTERPRISES, LLC, LONTRAC INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
On August 6, 2024, petitioner filed two motions to lodge certain documents from the administrative file, which were lodged with the motions. [Docs. 178-81.] Specifically, the first motion sought leave to lodge the activity record of an IRS examining officer that had been obtained in the course of informal discovery. [Docs. 178-79.] The second motion sought to lodge an IRS Notice of Proposed Adjustment, which again had been produced in informal discovery. [Docs. 180-81.]
We will deny both motions for leave. The documents lodged with the Court appear to be in the nature of evidence that petitioner wishes the Court to consider. The Court's rules permit the introduction of such evidence through the stipulation process or as proposed trial exhibits with ultimate admissibility determined at trial.
Although we deny the motions for leave, petitioner of course may seek to introduce the documents into evidence using either of the mechanisms described above.
Upon due consideration, it is
ORDERED that petitioner's motion for leave to file report [Doc.178] filed August 6, 2024, is denied. It is further
ORDERED that petitioner's motion for leave to file administrative record [Doc. 180] filed August 6, 2024, is denied.