Opinion
12930-21S
09-15-2021
Patricia A. Wheeler Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
Maurice B. Foley Chief Judge
On April 16, 2021, a petition was filed to commence the above-docketed case. That petition had not born petitioner's original signature. Subsequently, on September 7, 2021, petitioner filed both a Ratification of Petition and a signed copy of the petition, with certain attachments.
The foregoing considered, it is
ORDERED that, to clarify the record, the document filed September 7, 2021, as a Petition shall be recharacterized as a First Amended Petition. Petitioner is advise that evidentiary materials generally are not filed with the Court; rather, they should be exchanged with counsel for the Internal Revenue Service (IRS) as part of the pretrial process (before trial) and then introduced at trial if the case has not been settled prior thereto. Because the IRS is separate from this Court, petitioner is accordingly advised to contact IRS counsel directly regarding such matters.
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