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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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