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Petitioners admit the following facts. Petitioner is a
self-employed "Cheikh, or man of the cloth,"1 in San Diego,
California. During 1992, he received compensation for his
services in that capacity. During 1992, petitioners had checking
and savings accounts at Wells Fargo Bank. Petitioners also had a
checking account at Bank of America in 1992. They had no other
bank accounts. We deem the following facts to be admitted.
Petitioners deposited in their bank accounts a total of
$28,887.90, all of which was compensation to petitioner for his
services in 1992. Petitioners received but did not report $36 in
interest income in 1992. Petitioners reported gross receipts of
$7,255 from petitioner's business on Schedule C of petitioners'
income tax return for 1992.
B. Summary Judgment
We may grant summary judgment if the pleadings, answers to
interrogatories, depositions, admissions, affidavits, and any
other acceptable materials show that there is no genuine issue of
material fact and 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). Summary judgment is
appropriate where, as a result of facts deemed admitted under
Rule 90(c), there is no genuine issue of material fact. Marshall
1The record does not describe petitioner's position further.
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