- 6 -
754 (1988); Naftel v. Commissioner, 85 T.C. 527, 529 (1985). The
moving party bears the burden of showing that there is no genuine
issue of material fact, and factual inferences are viewed in the
light most favorable to the nonmoving party. See Preece v.
Commissioner, 95 T.C. 594, 597 (1990). The existence of any
reasonable doubt as to a material fact will result in denial of
the motion for summary judgment. See Hoeme v. Commissioner, 63
T.C. 18, 20 (1974). A fact is material if it "'tends to resolve
any of the issues that have been properly raised by the
parties.'" Boyd Gaming Corp. v. Commissioner, 106 T.C. 343, 347
(1996)(quoting 10A Wright et al., Federal Practice and Procedure:
Civil, sec. 2725, at 93 (2d ed. 1983)). Where both parties move
for summary judgment, each motion must be examined to determine
whether it has been established that there is no genuine issue as
to any material fact and that a decision may be entered as a
matter of law. See Take v. Commissioner, 82 T.C. 630, 633
(1984), affd. 804 F.2d 553 (9th Cir. 1986).
We agree with the parties that there are no material facts
at issue with regard to whether petitioner filed a valid 1995
Federal income tax return. Having determined that this is a
proper case for summary judgment, we focus on the legal
requirements of what constitutes a Federal income tax return.
Section 6011(a) provides that "any person made liable for
any tax * * * shall make a return * * * according to the forms
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