Opinion
453-17
03-23-2022
Gregory J. Podlucky & Karla S. Podlucky Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
ALBERT G. LAUBER, JUDGE
This case was tried on October 5 and 7 during the Court's October 4, 2021, Los Angeles, Cali fornia, trial session. The parties and witnesses appeared remote ly via Zoomgov. On January 21, 2022, the parties filed simultaneous opening briefs.
On March 21, 2022, at docket entry 311, petitioners filed their simultaneous answering brief and at docket entry 312 filed 448 pages of exhibits. These appear to be in the nature of evidence. All documents not stipulated must be proposed as trial exhibits, subject to objection by the opposing party, and the Court must rule on any objections before documents can become part of the record. Documents cannot be interjected into the record as attachments to pleadings or briefs. In any event, as we explained in our October 26, 2021, Order, the record in this case closed on October 14, 2021, and new evidence cannot be added to the record now.
In consideration of the foregoing, it is
ORDERED that the Exhibits filed on March 21, 2022, at docket entry 312, are stricken from the record of this case.