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contends that there is no dispute as to any material fact
regarding this levy action and that respondent’s determination to
proceed with collection of petitioner’s outstanding Federal
income tax liabilities for 1993 and 1994 by levy should be
sustained as a matter of law.
Summary adjudication is a procedure designed to expedite
litigation and avoid unnecessary, time-consuming, and expensive
trials. Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681
(1988). Summary adjudication may be granted with respect to all
or any part of the legal issues presented “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); see 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, and factual inferences will be read in a manner most
favorable to the party opposing summary adjudication. Dahlstrom
v. Commissioner, 85 T.C. 812, 821 (1985).
As explained in detail below, there is no genuine issue as
to any material fact, and a decision may be rendered as a matter
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