Molner v. Comm'r of Internal Revenue

Full title: DAVID MOLNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Court: United States Tax Court

Date published: Jun 21, 2024

No. 10028-24 (U.S.T.C. Jun. 21, 2024)

Opinion

10028-24

06-21-2024

DAVID MOLNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Kathleen Kerrigan, Chief Judge

ORDER

Kathleen Kerrigan, Chief Judge

On June 20, 2024, petitioner made eight electronic filings, designating the filing at Docket Index No. 6 as a Memorandum in Support of Petition, the filing at Docket Index No. 7 as an Affidavit of David Molner in Support of Memorandum in Support of Petition; and the filings at Docket Index Nos. 8 through 13 as Exhibit(s).

The filing at Docket Index No. 6 is in the nature of a First Amendment to Petition and will be so recharacterized. The filing at Docket Index No. 7 contains additional statements of facts in support of the Petition, as well as an exhibit list for evidentiary documents, which are contained in petitioner's filings at Docket Index Nos. 8 through 13.

Petitioner's filings contain documents in the nature of evidence. We therefore inform petitioner that those 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.

If, in an effort to settle this matter before trial, petitioner would like respondent (i.e., the Internal Revenue Service) to review and consider certain documents, petitioner may provide those documents directly to the attorney who will be representing respondent in this matter. The contact information for that attorney will be included in the Answer that respondent files to the Petition. Respondent has 60 days from the date of service of the First Amended Petition within which to file the Answer.

For further information, petitioner may consult "Guidance for Taxpayers" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.

Upon due consideration and for cause, it is

ORDERED that petitioner's filing at Docket Index No. 6 is recharacterized as petitioner's First Amendment to Petition. It is further

ORDERED that petitioner's filing at Docket Index No. 7 is recharacterized as petitioner's Exhibit(s). It is further

ORDERED that at this time no further action will be taken with respect to petitioner's Exhibit(s).