Opinion
5734-24S
05-14-2024
ORDER
Kathleen Kerrigan Chief Judge
On May 13, 2024, petitioner made an electronic filing with the Court at Docket Index No. 7, designating the filing as a "First Amendment to Attachment to Petition." Review of the filing shows that it consists of a document in the nature of evidence. Petitioner is therefore informed that the document has not been received into evidence by the Court, 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.
If, in an effort to settle this matter before trial, petitioner would like respondent (i.e., the Internal Revenue Service) to review and consider certain documents, petitioner may provide those documents directly to the attorney who will be representing respondent in this matter. The contact information for that attorney will be included in the answer that respondent files to the Petition. Respondent has 60 days from the date of service of the Petition within which to file the answer.
For further information, petitioner may consult "Guidance for Petitioners" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.
Upon due consideration and for cause, it is
ORDERED that petitioner's filing at Docket Index No. 7 is recharacterized as petitioner's Exhibit(s).