Opinion
17190-23
08-02-2024
MANUEL SANTIAGO H. VALLES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Peter J. Panuthos, Special Trial Judge
By Notice served June 11, 2024, this case is calendared for trial during the Court's November 4, 2024 Washington, D.C. trial session. On July 17, 2024, petitioner made an electronic filing designated as petitioner's Administrative Record (Docket Index No. 11), which is improperly titled. This filing appears to be documents in the nature of evidence.
The Tax Court is separate and independent from the Internal Revenue Service. Petitioner is advised that the above-referenced documents have not been received into evidence by the Court at this time. Petitioner is further advised that proposed documentary evidence should be provided to respondent (i.e., the Internal Revenue Service) to review and consider. Such documents should be exchanged with respondent in an effort to reach a settlement before any trial in this case. Petitioner should provide those documents directly to respondent's counsel. The contact information for respondent's counsel will be included in respondent's Answer, filed December 12, 2023. The appropriate time to present documentary evidence for inclusion in the Court's record is by (1) getting an agreement from respondent and entering into a stipulation of facts or (2) offering the documents into evidence at the trial.
For more information, petitioner may consult "Guidance for Petitioners" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.
Upon due consideration, it is
ORDERED that petitioner's Administrative Record filing on July 17, 2024, at Docket Index No. 11, is deemed stricken from the record in this case.