Opinion
22069-22
04-14-2023
GALINA NKONDA SILVESTRE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan Chief Judge
On April 12, 2023, petitioner electronically filed a document improperly titled Brief in Support of Answer. Upon due consideration, it is
ORDERED that petitioner's Brief in Support of Answer is recharacterized as an Exhibit. It is further
ORDERED that petitioner is advised that the above-described document appears to be a document in the nature of evidence. This document has 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 seeks to have respondent review and consider documents in an effort to reach a settlement in this case prior to trial, petitioner 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 December 13, 2022. For more information, petitioner's attention is invited to "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.