Opinion
10154-24
08-12-2024
GLENN R. VILLA & JILL S. ANDREWS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge
On August 9, 2024, petitioners filed documents designated as a Motion for Reconsideration of Findings or Opinion Pursuant to Rule 161 in the above-docketed matter.
Because most if not all of these documents appear to be evidentiary in nature, it is
ORDERED that petitioners' Motion for Reconsideration of Findings or Opinion Pursuant to Rule 161 is recharacterized as petitioners' Proposed Trial Exhibits. Petitioners are advised that these documents have not been received into evidence by the Court.