Joyce M. and Thomas J. Hamm - Page 3

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          cases cited thereat.  The factual materials and the inferences to           
          be drawn from them must be viewed in the light most favorable to            
          the party opposing the motion.  Blanton v. Commissioner, 94 T.C.            
          491, 494 (1990).  The opposing party cannot rest upon mere                  
          allegations or denials set forth in that party's pleadings,                 
          O'Neal v. Commissioner, supra at 674, and must make a showing               
          sufficient to establish the existence of each element essential             
          to that party's case and on which that party will bear the burden           
          of proof at trial, Celotex Corp. v. Catrett, 477 U.S. 317, 322              
          (1986) (interpreting Fed. R. Civ. P. 56(c), on which Rule 121(b)            
          is based).                                                                  
               In deciding the instant motion, we set forth a summary of              
          the facts relevant to our discussion.  Rule 121(b); Sundstrand              
          Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965           
          (7th Cir. 1994).  The facts presented below are based on the                
          parties' pleadings and moving papers, and other relevant                    
          materials in the record and are viewed in terms most favorable to           
          petitioners.  Blanton v. Commissioner, supra at 494.                        
               At the time they filed their petition in the instant case,             
          petitioners resided in Marietta, Georgia.  During at least                  
          January through July 1992, petitioner was employed by                       
          International Business Machines Corp. (IBM).  On July 28, 1992,             
          petitioner was informed by his manager, Catherine F. Allman, that           
          the project to which he was assigned would no longer be funded              

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