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interest on $14,611 pursuant to section 6653(b)(1)(B), and $3,653
pursuant to section 6661.
Petitioner timely filed a petition with the Court.
Petitioner disagrees with the following adjustments in the notice
of deficiency: (1) Calculation of $14,611 as the amount of the
deficiency; (2) additions to tax for fraud pursuant to section
6653(b); and (3) addition to tax for substantial understatement
pursuant to section 6661.
On February 10, 2003, respondent moved for summary judgment.
On March 10, 2003, petitioner filed a response opposing summary
judgment. On March 24, 2003, we heard oral argument on the
motion.
Discussion
Summary judgment under Rule 121 is derived from rule 56 of
the Federal Rules of Civil Procedure. In any question turning on
the interpretation of Rule 121, the history of rule 56, Federal
Rules of Civil Procedure, and the authorities interpreting such
rule are considered by the Court. See Hoeme v. Commissioner, 63
T.C. 18, 21 (1974).
Rule 121(a) provides that either party may move for summary
judgment upon all or any part of the legal issues in controversy.
Summary judgment is intended to expedite litigation and avoid
unnecessary and expensive trials. Fla. Peach Corp. v.
Commissioner, 90 T.C. 678, 681 (1988). Summary judgment is
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