Patricia R. Carpentier - Page 9

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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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