Charles and Martha McHan - Page 5

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          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); 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).  A motion for summary                
          judgment will not be granted if there is a genuine issue of                 
          material fact.  Gulfstream Land & Dev. Corp. & Subs. v.                     
          Commissioner, 71 T.C. 587 (1979).  The existence of any                     
          reasonable doubt as to the facts will result in denial of the               
          motion for summary judgment.  Hoeme v. Commissioner, 63 T.C. 18,            
          20 (1974).                                                                  
          Motion 1                                                                    
               In Motion 1, Charles argues that the notice of deficiency is           
          arbitrary and erroneous, and, therefore, not entitled to a                  
          presumption of correctness.  Charles asserts that he was a mere             
          conduit or agent and did not have any ownership in the illegal              
          funds or profits.  Furthermore, Charles claims that respondent              




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