Opinion
4999-23S
06-02-2023
PATRICIA ANN POL, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
Upon due consideration, it is
ORDERED that petitioner's Administrative Record, filed May 31, 2023, is recharacterized as an Exhibit. It is further
ORDERED that petitioner is advised that the above-described Exhibit appears to consist of 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. In the future, 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 may be found in respondent's Answer to the petition, filed May 23, 2023. For more information, petitioner's attention is invited to "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.