Opinion
5411-24
04-09-2024
ORDER
Kathleen Kerrigan, Chief Judge
On April 5, 2024, petitioner made several electronic filings, among them (1) three filings at Docket Index Nos. 6 through 8, each of which petitioner designated as an "Administrative Record," and (2) a filing at Docket Index No. 9, which petitioner designated as a "Memorandum in Support of Administrative Record." On April 8, 2024, petitioner filed a document at Docket Index No. 11, which petitioner designated as an "Unsworn Declaration of Joshua Woods Under Penalty of Perjury in Support of Petition." The foregoing filings appear to include documents in the nature of evidence. Petitioner is therefore informed that those documents have not been received into evidence by the Court, 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.
If, in an effort to settle this matter before trial, petitioner would like respondent (i.e., the Internal Revenue Service) to review and consider certain documents, petitioner may provide those documents directly to the attorney who will be representing respondent in this matter. The contact information for that attorney will be included in the answer that respondent files to the Petition. Respondent has 60 days from the date of service of the Petition within which to file the answer.
For further information, petitioner may consult "Guidance for Petitioners" under the "Rules & Guidance" tab on the Court's website at www.ustaxcourt.gov.
Upon due consideration and for cause, it is
ORDERED that petitioner's above-referenced filings at Docket Index Nos. 6 through 9 and Docket Index No. 11 are recharacterized as petitioner's Exhibit(s). It is further
ORDERED that at this time the Court will take no further action with respect to petitioner's Exhibit(s).