Opinion
33685-21S
01-09-2023
MATTHEW PAUL WILSON & KIMBERLY ANN WILSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On January 3, 2023, petitioners electronically filed the following improperly titled documents: (1) Answer (Doc. 7); (2) Memorandum in Support of Answer (Doc. 8); (3) Memorandum in Support of Answer (Doc. 9); and (4) Memorandum in Support of Answer (Doc. 10).
On January 4, 2023, petitioners electronically filed the following improperly titled documents: (1) Answer (Doc. 11); (2) Memorandum in Support of Answer (Doc. 12); (3) Memorandum in Support of Answer (Doc. 13); (4) Memorandum in Support of Answer (Doc. 14); (5) Answer (Doc. 15); (6) Memorandum in Support of Answer (Doc. 16); (7) Memorandum in Support of Answer (Doc. 17); and (8) Memorandum in Support of Answer (Doc. 18).
Upon due consideration, it is ORDERED that each of the above-described documents is recharacterized as a Report. It is further
ORDERED that petitioners are advised that the above-described documents appear to be documents in the nature of evidence. These documents have not been received into evidence by the Court at this time and, unless otherwise directed by the Court, the proper time to present documentary evidence for inclusion in the Court's record is at the trial of this matter. In the future, if petitioners seek to have respondent review and consider documents in an effort to reach a settlement in this case prior to trial, petitioners shall provide those documents directly to respondent's counsel, rather than filing them with the Court. The contact information for respondent's counsel is included in respondent's Answer to the petition, filed February 2, 2022. For more information, petitioners' attention is invited to "Guidance for Petitioners" under "Rules & Guidance" on the Court's website, www.ustaxcourt.gov.