Michael T. Hawkins and Janine M. Hansen - Page 14

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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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