Lottie Tyler Richardson - Page 2

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               Summary judgment 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 judgment 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 judgment.  Dahlstrom v.             
          Commissioner, 85 T.C. 812, 821 (1985).  The facts material to the           
          Court’s disposition of the motion for summary judgment are stated           
          solely for purposes of deciding the motion and are not findings             
          of fact for this case.  See Sundstrand Corp. v. Commissioner,               
          supra at 520.                                                               
                                     Background                                       
          Petitioner’s 1995 and 1996 Income Tax Liabilities                           
               On March 27, 1997, and June 5, 1997, petitioner filed her              
          Federal income tax returns for 1995 and 1996, respectively.  Due            






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