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"complete failure of proof" in the record on an essential element
of respondent's case. Petitioner has failed to make the initial
showing required by Rule 121(b) and Celotex Corp. v. Catrett, 477
U.S. 317 (1986). We, as a result, find that petitioner has
failed to show that there is no genuine issue as to any
materialfact and that a decision may be rendered as a matter of
law as to the deficiency and additions to tax for the year 1982.
We therefore deny petitioner's motion for partial summary
judgment.
An appropriate order
will be issued.
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