Opinion
14759-23
10-17-2023
RUSSELL L. PANTLEO, JR., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On October 12, 2023, petitioner filed a Letter Dated September 29, 2023, to which a number of documents are attached, including a Form 2848, Power of Attorney and Declaration of Representative. Petitioner is advised that most of the just-described documents 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. Petitioner is further advised that this Court, unlike the IRS, does not recognize powers of attorney.
Upon due consideration, it is
ORDERED that, if petitioner seeks to have respondent review and consider documents in an effort to reach a settlement in this case prior to trial, petitioner shall provide those documents directly to respondent's counsel, rather than filing them with the Court. The contact information for respondent's counsel will be included in respondent's Answer to the Petition, which is due on or before November 17, 2023. For more information, petitioner's 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 petitioner's above-referenced filings at this time.
Petitioner is reminded that his Ratification of Petition is due to be filed on or before November 6, 2023.