Opinion
13479-20S
03-24-2023
SEAN PAUL POLETE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden Special Trial Judge
This case was calendared for trial at the March 20, 2023, Cincinnati, remote Trial Session of the Court. On March 23, 2023, the Court held a trial in this case.
The Court would like to give the parties an opportunity to further provide their legal arguments relevant to the facts submitted into the record, and therefore the Court will direct each of the parties to file a memorandum of law. The parties are reminded that the memorandum of law should include solely legal arguments and not propose new facts outside of the scope of what was presented at trial.
Accordingly, it is
ORDERED that, on or before May 22, 2023, petitioner shall file a Memorandum of Law in which he responds to the above-described issue. It is further
ORDERED that, on or before May 22, 2023, respondent shall file a Memorandum of Law in which he addresses the above-described issue.