Opinion
10226-21L
09-12-2022
ISANG E. UMOREN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro Judge
This case is calendared for trial during the Court's September 15, 2022, Washington, D.C., special trial session. In anticipation of trial, respondent filed Proposed Trial Exhibits (Doc. 70). Although the Proposed Trial Exhibits contain lead cover sheets (for example, Exhibit 1000-R, Exhibit 1001-R, and so on), the pages within each exhibit do not include the exhibit numbers and are not uniquely numbered for the Court and parties to identify specific pages within documents easily. Moreover, many of the exhibits contain their own exhibits (for example, Exhibit 1000-R, which is nearly 600 pages long, contains within it Exhibits A through DD). The pages within those lettered (or numbered) exhibits are also not uniquely numbered and are not labeled with the relevant exhibit letter (or number). The Court anticipates this would make it difficult during the trial to identify where specific materials appear.
To address the foregoing, upon due consideration, it is hereby
ORDERED that, no later than 5:00 p.m. (Eastern Time) on Tuesday, September 13, 2022, respondent shall file its proposed exhibits in compliance with the Court's procedures as explained in "Documentary Evidence for Remote Proceedings", found on the Court's website at:
https://www.ustaxcourt.gov/resources/covid/documentary_evidence.pdf.
Respondent should retain the numbering and the ordering of its previous filing. When a document (such as, for example, Exhibit 1000-R) includes its own exhibits, it should contain a label indicating both the overall exhibit of which it is a part and the subsidiary exhibit letter or number. For example, each of the pages that make up Exhibit A that is part of Exhibit 1000-R should be labeled "Exhibit A of Exhibit 1000-R" and should also include a unique identifying number.