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taxes and other miscellaneous expenses incurred during the years
in issue. Respondent's Second Request for Admissions and
respondent's Amendment to Answer are silent with respect to the
nature and amount of the deductions to which petitioner may be
entitled for the years in issue.
Under the circumstances, we will grant respondent partial
summary judgment in that petitioner will be precluded from
contesting the matters set forth in respondent's Second Request
for Admissions and respondent's Amendment to Answer. However, we
hold that respondent is not entitled to full summary judgment
insofar as material issues of fact remain in dispute with respect
to petitioner's entitlement to various deductions for the years
in issue. Any trial in this case will therefore be limited to
the issue of the nature and amount of petitioner's deductions for
the years in issue.
To reflect the foregoing,
An order granting respondent
partial summary judgment will be
issued.
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Last modified: May 25, 2011