- 2 -
7491(c), I.R.C., is of no consequence if P’s
assignments of error have been struck.
Elena Swain, pro se.
Jonathan H. Sloat, for respondent.
OPINION
HALPERN, Judge: This case is before the Court on
respondent’s motion for summary judgment (the motion).
Petitioner objects.
Unless otherwise stated, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
Rule 121 provides for summary judgment. Summary judgment
may be granted with respect to all or any part of the legal
issues in controversy “if the pleadings, answers to
interrogatories, 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(a) and
(b).
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Last modified: May 25, 2011