Robert Hunter Gridley and Barbara A. Gridley, et al. - Page 11

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          maintain that the piggyback agreements that they executed provide           
          for entry of decision in their cases once there is a "final                 
          decision" in the test cases.  Petitioners assert that they are              
          entitled to entry of decision in their cases consistent with the            
          decision entered in the Thompson case assigned docket No. 19321-            
          83 on the grounds that the latter decision is final and                     
          represents the most favorable of the decisions entered in the               
          Thompson and Cravens cases.                                                 
               Respondent objects to petitioners' Motions for Summary                 
          Judgment on the ground that petitioners misinterpret the                    
          piggyback agreements.  Specifically, respondent asserts that the            
          piggyback agreements reflect the parties' agreement to be bound             
          by the Court's opinion in the test cases as opposed to the                  
          decision entered in a particular test case.                                 
          Discussion                                                                  
          Summary judgment is intended to expedite litigation and                     
          avoid unnecessary and expensive trials.  Florida Peach Corp. v.             
          Commissioner, 90 T.C. 678, 681 (1988).  Summary judgment upon all           
          or any part of the legal issues in controversy is appropriate "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.               





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