Opinion
2784-19
01-06-2022
Lori Michelle Patitz & Andrew Robert Moody Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Christian N. Weiler Judge
This case was calendared for trial at the the Court's December 13, 2021, Jacksonville, Florida remote trial session. On November 29, 2021, Petitioners filed two sets of Proposed Trial Exhibits, both marked as 1001-P (Index #26 and #27)
This case was called and recalled on December 13, 2021, at the Court's December 13, 2021, Jacksonville, Florida remote trial session. Both petitioners and counsel for respondent appeared before the Court and were heard. At that time a trial was held. After due consideration and for cause more fully appearing in the transcripts of the proceeding, it is
ORDERED that petitioner's pre-trial exhibit filed on November 29, 2021 (Index #26), marked 1001-P is erroneous and shall be stricken from the record. It is further
ORDERED that petitioner's pre-trial exhibit filed on November 29, 2021 (Index #27), marked 1001-P shall be re-labeled as 1005-P. It is further
ORDERED that petitioner's Oral Motion to Amend Pleadings to Conform to the Evidence is hereby granted. It is further
ORDERED the petitioner shall, on or before February 28, 2022, file with the court a written opening brief not to exceed twenty-five written pages. It is further
ORDERED the respondent shall, on or before April 14, 2022, file with the court a written answering brief not to exceed twenty-five written pages. It is further
ORDERED the petitioner shall, if they so choose, file with the court a written reply brief not to exceed fifteen written pages on or before May 16, 2022.