Opinion
25974-17
11-10-2021
Michael Zorn, Petitioner v. Commissioner of Internal Revenue, Respondent
ORDER
Courtney D. Jones Judge
On October 15, 2021, respondent filed a Motion in Limine (docket entry no. 68). On October 20, 2021, respondent again filed a Motion in Limine (docket entry no. 70). This case was called for a partial trial at the Court's Baltimore, Maryland Trial Session, conducted remotely on November 3, 2021. Both parties appeared and were heard. For reasons appearing more fully in the transcript of the proceedings, the Court will grant respondent's aforementioned motions.
At the commencement of trial, respondent made an oral motion for leave to substitute exhibit 4-J of the First Stipulation of Facts, filed electronically on May 20, 2019 (docket entry no. 30), upon the grounds that it is not legible.
A legible copy of exhibit 4-J was attached at pages 174 to 315 of respondent's Proposed Trial Exhibits, electronically filed on October 15, 2021 (docket entry no. 69). However, the parties are required to follow the proper procedures to substitute the exhibit explained herein.
Further, respondent also made an oral motion for leave to substitute exhibit 68-R attached to respondent's Proposed Trial Exhibits, filed electronically October 15, 2021, upon the grounds that it contains unredacted information. Petitioner did not object to either oral motion for leave to substitute. Unfortunately, the Court cannot substitute pages in electronically filed documents.
Accordingly, it is
ORDERED that respondent's Motion in Limine (docket entry no. 68), filed October 15, 2021, is granted. It is further
ORDERED that respondent's Motion in Limine (docket entry no. 70), filed October 20, 2021, is granted. It is further
ORDERED that respondent's oral motion for leave to substitute exhibit 4-J of the First Stipulation of Facts, made November 3, 2021, is granted in that, on or before January 18, 2022, the parties shall file a complete Amended First Stipulation of Facts, in its entirety, incorporating the corrected pages of exhibit 4-J. It is further
ORDERED that respondent's oral motion for leave to substitute exhibit 68-R of respondent's Proposed Trial Exhibits, made November 3, 2021, is granted in that, on or before January 18, 2022, respondent shall file an Amendment to Proposed Trial Exhibits, in its entirety, incorporating the corrected pages of exhibit 68-R.