Opinion
23002-19
05-02-2023
NICOLE D. SPRUILL, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
TAMARA W. ASHFORD JUDGE.
This case was called for trial at 1:00 p.m. on April 17, 2023, at the Trial Session of the Court at Winston-Salem, North Carolina commencing on April 17, 2023. During the trial, the Court ordered that the record be held open for the limited purpose of receiving a Fourth Stipulation of Facts that identifies (and attaches as exhibits as the case may be) the following: (1) petitioner's proposed exhibits that were proffered and admitted by the Court during trial; (2) pursuant to I.R.C. § 6015(e)(7)(A), the paper administrative record established at the time of the determination; (3) pursuant to I.R.C. § 6015(e)(7)(A), electronically maintained documents that respondent considers part of the administrative record established at the time of the determination; and (4) pursuant to I.R.C. § 6015(e)(7)(B), any additional newly discovered or previously unavailable evidence. On April 26, 2023, pursuant to the Court's instruction, the parties filed a Fourth Stipulation of Facts, which attached already admitted Exhibits 68-P through 77-P, already admitted Exhibits 81-R through 87-J, and Exhibit 88-J. Exhibit 88-J is a copy of the entire paper administrative record established at the time of the determination. Upon due consideration, it is hereby
ORDERED that the parties' Fourth Stipulation of Facts (including Exhibit 88-J attached thereto), filed April 26, 2023, is admitted into evidence. It is further
ORDERED that the evidentiary record in this case is now closed.