Yvonne E. Thurner - Page 9

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          Consistent with these statements, petitioner Yvonne E. Thurner’s            
          affidavit states that, prior to the time she claimed relief from            
          joint and several liability under section 6015, all of the                  
          family’s tax matters were handled exclusively by her husband.               
               Pursuant to notice, these cases were called for hearing at             
          the Court’s motions session in Washington, D.C.  Following the              
          hearing, respondent filed supplements to his motions describing             
          the bases for the assessments entered against petitioners for               
          1990 and 1992 and providing transcripts of account for the years            
          in issue.                                                                   
          Discussion                                                                  
          Summary judgment is intended to expedite litigation and                     
          avoid unnecessary and expensive trials.  See 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 in              
          controversy “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(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);                
          Naftel v. Commissioner, 85 T.C. 527, 529 (1985).  The moving                
          party bears the burden of proving that there is no genuine issue            






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