Opinion
12999-24
09-26-2024
ORDER
Kathleen Kerrigan Chief Judge
On September 25, 2024, petitioner David J. Menard filed a document titled Exhibit(s), which appears to be a document in the nature of evidence. The Tax Court is separate and independent from the Internal Revenue Service. Petitioner is advised that the just-referenced document has not been received into evidence by the Court at this time 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.
Petitioner is further advised that in the future, unless otherwise directed, if petitioner seeks to have the Commissioner (respondent) review and consider documents in an effort to reach a settlement before any trial in this case, petitioner should provide those documents directly to respondent's counsel. The contact information for respondent's counsel will be included in respondent's Answer, which is due to be filed on or before October 11, 2024. For more information, petitioner may consult "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.
Upon due consideration, it is
ORDERED that petitioner's above-referenced Exhibit(s) is recharacterized as a Proposed Trial Exhibit. The Court will take no action with respect to that document at this time.