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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. See
Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985); Jacklin v.
Commissioner, 79 T.C. 340, 344 (1982).
As previously discussed, petitioner is deemed to have
admitted the various matters set forth in respondent's Second
Request for Admissions and respondent's Amendment to Answer.
There is no dispute as to any material fact as to the matters set
forth therein. The allegations deemed admitted, quoted above in
their entirety, establish the nature and amount of various items
of income that petitioner failed to report during the years in
issue. The allegations deemed admitted also establish that
petitioner is liable for the additions to tax determined in the
notices of deficiency.
Petitioner opposes respondent's Motion for Summary Judgment
on the ground that she is entitled to deductions for real estate
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