Opinion
24679-22
02-01-2023
STEPHANIE DAWN SHEEHAN & RYAN FRANCIS SHEEHAN, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On January 31, 2023, among other things, petitioners electronically filed three documents titled Exhibit(s) (Docs. 9, 10, and 12). Upon due consideration, it is
ORDERED that petitioners are advised that the above-described documents appear to be documents in the nature of evidence. These documents have not been received into evidence by the Court at this time and, unless otherwise directed by the Court, the proper time to present documentary evidence for inclusion in the Court's record is at the trial of this matter. In the future, if petitioners seek to have respondent review and consider documents in an effort to reach a settlement in this case prior to trial, petitioners shall provide those documents directly to respondent's counsel, rather than filing them with the Court. The contact information for respondent's counsel is included in respondent's Answer to the petition, filed January 17, 2023. For more information, petitioners' attention is invited to "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.