Opinion
19639-23S
01-12-2024
SHANNON C. NOLDER & JOSHUA R. NOLDER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 8, 2024, petitioner Shannon C. Nolder electronically filed with the Court the following improperly titled documents: (1) First Supplemental Petition, and (2) Declaration of Shannon C. Nolder in Support of First Supplemental Petition.
The above-described documents appear to be documents in the nature of evidence. Petitioners are advised that 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.
Upon due consideration, it is
ORDERED that the above-referenced First Supplemental Petition and Declaration of Shannon C. Nolder in Support of First Supplemental Petition are each recharacterized as an Exhibit. It is further
ORDERED that, if petitioners seek to have respondent review and consider documents in an effort 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, which is due to be filed on or before February 12, 2024. For more information, petitioners' attention is invited to "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov. It is further
ORDERED that the Court will take no action on the above-referenced filings at this time.