- 8 -
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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