Opinion
23072-22S
04-19-2023
MICHAEL C. LULOFF, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On March 2, 2023, petitioner filed four Exhibit(s). However, further review indicates that these filings appear to be more akin to Unredacted Letters.
Upon due consideration, it is
ORDERED that petitioner's four Exhibit(s), filed March 2, 2023, are recharacterized as petitioner's Unredacted Letters. It is further
ORDERED that petitioner's Unredacted Letters are sealed and shall not be inspected by any person or entity not a party to this case, except by an Order of the Court.
Petitioner is advised that the above-described documents appear to be in the nature of evidence. These documents have not been received into evidence by the Court at this time and, unless otherwise directed by the Court, the proper time to present documentary evidence for inclusion in the Court's record is at the trial of this matter. In the future, if petitioner seeks to have respondent review and consider documents in order to reach a settlement in this case prior to trial, petitioners shall provide those documents directly to respondent's counsel, rather than filing them with the Court. The contact information for respondent's counsel is included in respondent's Answer to the petition, filed December 22, 2022. For more information, petitioner's attention is directed to "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.