Stanley B. and Rose M. Whitten - Page 2

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               This case is before the Court on the parties' cross-motions            
          for summary judgment.  The issue for decision concerns the proper           
          characterization of expenses incurred by petitioner Stanley B.              
          Whitten in attending and participating in the television game               
          show "Wheel of Fortune".                                                    
          Summary judgment is intended to expedite litigation and                     
          avoid unnecessary and expensive trials.  Florida Peach Corp. v.             
          Commissioner, 90 T.C. 678, 681 (1988).  Summary judgment may be             
          granted with respect to all or any part of the legal issues in              
          controversy "if the pleadings, answers to interrogatories,                  
          depositions, admissions, and any other acceptable materials,                
          together with the affidavits, if any, show that there is no                 
          genuine issue as to any material fact and that a decision may be            
          rendered as a matter of law."  Rule 121(b); Sundstrand Corp. v.             
          Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th               
          Cir. 1994); Zaentz v. Commissioner, 90 T.C. 753, 754 (1988);                
          Naftel v. Commissioner, 85 T.C. 527, 529 (1985).  The moving                
          party bears the burden of proving that there is no genuine issue            
          of material fact, and factual inferences will be read in a manner           
          most favorable to the party opposing summary judgment.  Dahlstrom           



          1(...continued)                                                             
          the Internal Revenue Code in effect for the taxable year in                 
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     




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