Opinion
5526-24
06-04-2024
MICHAEL E. PRAX & VALERIE J. PRAX, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge.
On May 24, 2024, respondent filed an Answer to Amended Petition. This filing was improperly titled and will be recharacterized.
Further, on May 26, 2024, petitioners filed two documents titled Exhibit(s), at Docket Index Nos. 13 and 14. The Tax Court is separate and independent from the Internal Revenue Service. Petitioners are advised that the above-referenced Exhibit(s) have not been received into evidence by the Court at this time and that, unless otherwise directed by the Court, the appropriate time to present documentary evidence for inclusion in the Court's record is at the trial of this matter.
Petitioners are further advised that in the future, unless otherwise directed, if they seek to have the Commissioner (respondent) review and consider documents in an effort to reach a settlement before any trial in this case, they should provide those documents directly to respondent's counsel. The contact information for that attorney is included in respondent's Answer to Amended Petition, filed May 24, 2024. For more information, petitioners may consult "Guidance for Taxpayers" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.
Upon due consideration, it is
ORDERED that respondent's Answer to Amended Petition is recharacterized as respondent's Answer to First Amended Petition, as Amended. It is further
ORDERED that the Court shall take no action on petitioners' above-referenced Exhibit(s) at this time.