Patricia R. Carpentier - Page 10




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          taxes and other miscellaneous expenses incurred during the years            
          in issue.  Respondent's Second Request for Admissions and                   
          respondent's Amendment to Answer are silent with respect to the             
          nature and amount of the deductions to which petitioner may be              
          entitled for the years in issue.                                            
               Under the circumstances, we will grant respondent partial              
          summary judgment in that petitioner will be precluded from                  
          contesting the matters set forth in respondent's Second Request             
          for Admissions and respondent's Amendment to Answer.  However, we           
          hold that respondent is not entitled to full summary judgment               
          insofar as material issues of fact remain in dispute with respect           
          to petitioner's entitlement to various deductions for the years             
          in issue.  Any trial in this case will therefore be limited to              
          the issue of the nature and amount of petitioner's deductions for           
          the years in issue.                                                         
               To reflect the foregoing,                                              


                                             An order granting respondent             
                                        partial summary judgment will be              
                                        issued.                                       













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