- 12 -
summary judgment and that petitioners have failed to come forward
with countervailing assertions having sufficient specificity to
cause us to hold that there is any material issue of fact which
requires a trial. Under these circumstances, respondent is
entitled to summary judgment as a matter of law. Rule 121(d);
Hibernia Nat. Bank v. Carner, 997 F.2d 94, 98 (5th Cir. 1993);
Abramo v. Commissioner, supra.8
Respondent's motions for summary
judgment will be granted and decisions
will be entered for respondent.
8 See also Daniels v. Commissioner, T.C. Memo. 1994-591.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12
Last modified: May 25, 2011