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Petitioners did not appear at the calendar call or otherwise
communicate with the Court.
Discussion
A. Summary Judgment
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. Commissioner, 85 T.C. 812, 821 (1985);
Jacklin v. Commissioner, 79 T.C. 340, 344 (1982). Matters deemed
admitted under Rule 90(c) are conclusively established and may be
considered in deciding whether to grant a motion for summary
judgment. Marshall v. Commissioner, 85 T.C. 267, 272-273 (1985);
Morrison v. Commissioner, 81 T.C. 644, 651-652 (1983); Doncaster
v. Commissioner, 77 T.C. 334, 336 (1981).
We have examined the entire record and construed facts most
favorably for petitioners. We conclude that there is no dispute
as to any material fact and that respondent is entitled to
summary judgment. Rule 121(b).
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