Opinion
16041-22
09-09-2024
MICHAEL H. SHAUT, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Courtney D. Jones Judge
The trial in this case took place during the Court's Cleveland, Ohio, trial session. At trial, the Court reserved ruling on four of petitioner Michael H. Shaut's proposed exhibits: Exhibits 9-P, 10-P, 12-P, and 13-P. The parties have now had an opportunity to brief their positions regarding these exhibits.
Respondent no longer objects to the admission of Exhibit 10-P or portions of Exhibit 9-P. Specifically, respondent does not object to admission of the 2013 and 2014 Forms 1065, U.S. Return of Partnership Income, contained in Exhibit 9-P. Accordingly, the Court will admit into evidence Exhibit 10-P and will direct the parties to file, as joint exhibits, the portions of Exhibit 9-P to which respondent does not object.
Moreover, for the reasons set forth in respondent's Simultaneous Opening Brief, the Court will sustain respondent's objections to Exhibits 12-P and 13-P, as well as the remainder of Exhibit 9-P. (See Doc. 39 at pp. 2-4). Upon due consideration, it is
ORDERED that the parties are directed to meet and confer regarding the portions of Exhibit 9-P to which respondent no longer objects (specifically, the 2013 and 2014 Forms 1065). They shall then submit two separate exhibits containing the 2013 and 2014 Forms 1065. The new exhibits shall be labeled 15-J and 16-J, respectively. The new exhibits shall be submitted on or before September 20, 2024. The Court sustains respondent's objections to the remainder of Exhibit 9-P. It is further
ORDERED that Exhibit 10-P is admitted into evidence. It is further
ORDERED that the Court sustains respondent's objections to Exhibits 12-P and 13-P.