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Discussion
A. Contentions of the Parties
Respondent contends, inter alia, that petitioners waived
their right to challenge collection of their tax liability for
1992-94 because they signed Form 4549 consenting to the immediate
assessment and collection of their tax liability for those years.
In their petition, petitioners stated as a basis for relief
only that:
We disagree with the determination, because although we
were present at the time of the original audit, many of
our deductions were disallowed when they were correct.
We have been requesting an audit reconsideration to
present general ledegers [sic] and documents properly
organized in order to verify our deductions in a
cohesive manner.
B. Summary Judgment
Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials. Fla. Peach Corp. v.
Commissioner, 90 T.C. 678, 681 (1988). 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). The moving party bears the burden of proving that
there is no genuine issue of material fact. Dahlstrom v.
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