Opinion
6446-19L
12-07-2021
Wendell C. Robinson & May T. Jung-Robinson Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
David Gustafson Judge
On December 2, 2021, the parties filed with this Court a First Stipulation of Facts ("Stipulation") (Doc. 78), to which they attached multiple exhibits. It appears that Exhibit 18-J, which is described in the stipulation (para. 23) as being a check written by petitioners to the U.S. Treasury in the amount of $39,438.45 is missing from the filed stipulation. Instead, a check written by petitioner May T. Jung-Robinson in the amount of $15,000.00 (which also appears as a part of Exhibit 11-J) is attached to the Stipulation and labelled as Exhibit 18-J. In addition, the stipulation states (at para. 32) that respondent's letter to petitioners dated April 20, 2016, is attached as Exhibit 24-J, but no item attached to the Stipulation bears the label "Exhibit 24-J". A letter dated April 20, 2016, bears the label "Exhibit 24-R". It is unclear whether the parties intended to attach a different letter as Exhibit 24-J or simply mislabeled the attached letter as "Exhibit 24-R". It is therefore
ORDERED that, no later than the time the case is called for trial on December 15, 2021, the parties shall file a revised First Stipulation of Facts that corrects these errors.