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amount of $1,917 for 1988. In total, petitioner did not report
income in the amounts of $17,018 and $31,638 on her Federal
income tax returns for taxable years 1987 and 1988, respectively.
After concessions by respondent, there are deficiencies in
petitioner's income tax in the amount of $3,333 for the taxable
year 1987 and in the amount of $5,844, including self-employment
tax of $1,045, for taxable year 1988.
Discussion
Respondent bases her motion for summary judgment on the
facts conclusively established by the deemed admissions.
Petitioner did not respond to the request for admissions or
oppose respondent's motion for summary judgment.
A motion for summary judgment may be granted "if the
pleadings, answers to interrogatories, depositions, admissions,
and any other acceptable materials * * * 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); O'Neal v.
Commissioner, 102 T.C. 666, 674 (1994); Bond v. Commissioner, 100
T.C. 32, 36 (1993). The moving party, however, bears the burden
of establishing that no genuine issue exists as to any material
fact. Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986);
Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd.
17 F.3d 965 (7th Cir. 1994); Espinoza v. Commissioner, 78 T.C.
412, 416 (1982). In deciding whether to grant summary judgment,
we consider the factual materials and draw inferences from them
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