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filed the summary judgment motion timely; (5) and whether the
representative of respondent has legal authority to act on behalf
of respondent. Petitioners, though, do not present the Court
with any specific facts showing any genuine issue for trial
despite this Court’s express requirement for such a showing. See
Rule 121(d). Petitioners’ repeated assertions of the existence
of questions of fact are insufficient and without foundation, and
we conclude that this case is appropriate for summary judgment.
A. Respondent’s Adjustments Are Sustained
1. Deficiencies
Gross income includes all income from whatever source
derived. Sec. 61(a). Respondent’s determinations in a notice of
deficiency are presumed correct. Welch v. Helvering, 290 U.S.
111, 115 (1933). Petitioners merely allege that respondent’s
determination of deficiencies in, and additions to, tax are
incorrect. The arguments they put forward are frivolous and
without merit.
Petitioners contend that the Individual Master File (IMF)
for each petitioner has incorrect information and that they have
no tax liability. Petitioners’ contentions, however, are blanket
statements, and they provide no support for their bare
allegations that there are genuine issues for trial. Moreover,
petitioners have not produced any information or set forth any
specific facts to contradict the gross income reflected on
petitioners’ W-2 statements and 1099 forms. We hold that there
is no genuine issue as to any material fact.
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