Opinion
2428-22S
03-22-2022
ORDER
MAURICE B. FOLEY, CHIEF JUDGE
On March 21, 2022, petitioners filed electronically in the above-docketed matter a document under the designation "Proposed Trial Exhibits", an improper characterization. Moreover, review of the record shows that the document consists in its entirety of copies of materials that appears to be potentially evidentiary in nature, submitted by petitioners in support of their position herein.
Although the Court previously on February 23, 2022, issued to petitioners a Notice of Attachments in the Nature of Evidence, the Court would again stress that evidentiary materials generally are not filed with the Court; rather, they should be exchanged with counsel for the Internal Revenue Service (IRS) as part of the pretrial process (before trial) and then introduced at trial if the case has not been settled prior thereto. Because the IRS is separate from this Court, petitioners are accordingly advised to contact IRS counsel directly regarding such matters.
Upon due consideration, it is
ORDERED that the document filed March 21, 2022, as "Proposed Trial Exhibits" is hereby deemed stricken from the Court's record in this case.