Opinion
10411-23S
11-13-2023
PAUL VILENO & PATRICIA VILENO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
KATHLEEN KERRIGAN, CHIEF JUDGE.
On October 30, 2023, petitioners submitted a set of documents to the Court. Those documents were initially filed on the same date as petitioners' Reply to Answer. However, upon further review, the Court notes that the documents consist of certain pages of the Petition, filed June 26, 2023; certain pages of the Answer, filed August 28, 2023; and documents in the nature of evidence. Accordingly, we will recharacterize the filing as set forth below.
Additionally, in view of the documents in the nature of evidence that petitioners have submitted to the Court, we inform petitioners that those documents have not been received into evidence, and that, unless otherwise directed by the Court, the appropriate time to present documentary evidence for inclusion in the Court's record is at the trial of this matter. Generally, evidentiary materials are not filed with the Court.
If, in an effort to settle this matter before trial, petitioners would like respondent (i.e., the Internal Revenue Service) to review and consider certain documents, such as those that have been filed with the Court, petitioners may provide those documents directly to the attorney representing respondent in this matter. Petitioners may find the contact information for that attorney in respondent's Answer.
For further information, petitioners may consult "Guidance for Petitioners" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.
In consideration of the foregoing, it is ORDERED that petitioners' Reply to Answer is recharacterized as petitioners' Exhibit(s).