Frederick M. Fox - Page 8

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          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); Naftel v. Commissioner, 85 T.C. 527, 529 (1985).  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); Jacklin v.              
          Commissioner, 79 T.C. 340, 344 (1982).  However, Rule 121(d)                
          states:                                                                     
               When a motion for summary judgment is made and                         
               supported as provided in this Rule, an adverse party                   
               may not rest upon the mere allegations or denials of                   
               such party's pleading, but such party's response, by                   
               affidavits or as otherwise provided in this Rule, must                 
               set forth specific facts showing that there is a                       
               genuine issue for trial.  If the adverse party does not                
               so respond, then a decision, if appropriate, may be                    
               entered against such party.                                            
          See Parkinson v. Commissioner, 647 F.2d 875, 876 (9th Cir. 1981),           
          affg. per curiam T.C. Memo. 1979-319; King v. Commissioner, 87              
          T.C. 1213, 1217 (1986); Marshall v. Commissioner, 85 T.C. 267,              
          271 (1985).                                                                 
          Petitioner's Motions for Summary Judgment                                   
               Petitioner's motions for summary judgment are founded upon             
          tax protester type arguments with respect to the deficiencies and           
          additions to tax determined by respondent.  All of the arguments            
          raised by petitioner have been uniformly rejected by this and               
          other courts.  See Abrams v. Commissioner, 82 T.C. 403 (1984);              
          Rowlee v. Commissioner, 80 T.C. 1111 (1983); McCoy v.                       




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