Opinion
8177-20
01-12-2022
David Villa & Juana M. Villa Petitioners v. Commissioner of Internal Revenue Respondent
ORDER
Elizabeth A. Copeland Judge
This case was called from the calendar at the Court's remote Houston, Texas trial session on November 1, 2021; and later for trial on November 3, 2021.
At the end of the trial, the Court ordered that the record be held open for the limited purpose of receiving Petitioners' complete 2016 and 2017 bank records.
On November 9, 2021, the parties filed with the Court a First Supplemental First Stipulation of Facts (docket index entry No. 23) and attached thereto a document labeled as Exhibit 7-J; a copy of Petitioners' bank statements for the taxable years 2016 and 2017. However, during trial, the Court renumbered respondent's Proposed Trial Exhibit 2-R filed on October 18, 2021 (at docket index entry No. 12) to 7-J and referred to 7-J as such throughout the transcript of the proceeding.
On January 6, 2022, the parties refiled a First Supplemental First Stipulation of Facts (docket index entry No. 24) and correctly labeled the attachment as Exhibit 8-J. Therefore, the Court will strike the parties' First Supplemental First Stipulation of Facts, filed November 9, 2021 (docket index entry No. 23).
After due consideration, and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that the parties' First Supplemental First Stipulation of Facts, filed November 9, 2021 (docket index entry No. 23), is stricken from the record in this case. It is further
ORDERED that the parties' Exhibit 8-J attached to First Supplemental First Stipulation of Facts (docket index entry No. 24), filed January 6, 2022, is admitted into the Court's record in this case. It is further
ORDERED that the evidentiary record is closed.