Opinion
15918-23
12-15-2023
TONGAI R. MAZAIWANA & MELODY MAZAIWANA, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On December 14, 2023, petitioners electronically filed four documents titled "First Amended Petition" (Docket Index Nos. 7-10).
Upon due consideration of the foregoing, it is
ORDERED that each of the above-described documents titled "First Amended Petition" (Docket Index Nos. 7-10) is recharacterized as an Exhibit.
Petitioners are advised that the above-described documents at Docket Index Nos. 7 through 10 appear to be documents 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 petitioners seek to have respondent review and consider documents in an effort to reach a settlement in this case prior to trial, petitioners should 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, which was filed on December 4, 2023. For more information, petitioners' attention is invited to "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.