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liable for additions to tax for fraud for the taxable years 1983
through 1987. Respondent asserts that she is entitled to summary
judgment with respect to these issues.
Petitioner responded to respondent's motions for summary
judgment by filing his own motions for summary judgment.
Petitioner's motions are based on the same frivolous arguments
set forth in his replies to respondent's answers.
A hearing was held on the pending motions in Washington,
D.C., on December 6, 1995. Counsel for respondent appeared at
the hearing and presented argument on the pending motions.
Although petitioner did not appear at the hearing, he filed
written statements with the Court pursuant to Rule 50(c).5
Discussion
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).]
5 Petitioner's Rule 50(c) statements consist of the same
tax protestor arguments that he has relied upon throughout these
proceedings.
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