Leslie R. Foster and Mattie J. Foster, et al. - Page 12

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          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.                   




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