Opinion
23305-18
07-18-2022
RALPH M. OTTUSO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth A. Copeland Judge
This case was calendared for trial at the July 11, 2022, Remote Special Trial Session of the Court where Washington, D.C. was listed as the place of trial. Petitioner, pro se, appeared and was heard. Respondent's counsel appeared and was heard.
During the trial, Respondent's counsel brought to the Court's attention that exhibit 16-J (Loan Note) was mislabeled as 17-J when submitted as part of the First Stipulation of Facts on September 28, 2020. An exhibit correctly labeled 17-J (Summary Exhibit Prepared by Petitioner Regarding Gross Receipts) was submitted as part of the First Supplemental First Stipulation of Facts filed on July 8, 2022. Respondent's counsel informed the Court that he will be filing supplemental documentation to correct the mislabeled 16-J exhibit. Additionally, during the trial, petitioner presented an additional exhibit to the Court that Respondent's counsel agreed to include as part of the electronic supplemental filing.
After due consideration, and for cause more fully appearing in the transcript of this proceeding, it is
ORDERED that on or before July 25, 2022, respondent shall file with the Court additional stipulations, proposed trial exhibits or other appropriate supplemental filing correcting the identification of the Loan Note as exhibit 16-J rather than 17-J. Such filing shall also electronically submit Petitioner's exhibit 25-P to the Court. It is further
ORDERED that this case is submitted as of July 11, 2022. However, the record of this case shall remain open until July 25, 2022 to receive supplemental filings. On July 25, 2022, the record of this case shall be closed and no more evidence nor supplemental filings will be received.