Anclote Psychiatric Center, Inc. - Page 2

                                                  -2-                                                   
            Respondent determined deficiencies in petitioner's Federal income                           
            tax for taxable years 1984 through 1988 as follows:                                         
                        Year              Deficiency                                                    
                        1984              $159,008                                                      
                        1985              110,623                                                       
                        1986              75,490                                                        
                        1987              45,444                                                        
                        1988              62,041                                                        

                  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).  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 v. Commissioner, 85 T.C. 812, 821 (1985).  The facts                              
            presented below do not appear to be in dispute and are stated                               


            and all Rule references are to the Tax Court Rules of Practice                              
            and Procedure.                                                                              




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