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scam.” Petitioners assert that, when they first heard about
claims for slavery reparations, they researched the Internal
Revenue Service’s website and found no mention of a scam relating
to the matter. They also contend that they first learned that
their slavery reparations claim was not legitimate when they were
interviewed by an IRS special agent in July 1999. They maintain
that the special agent informed them that they did not need to
repay the $80,000 in question, but that he would appreciate their
assistance in prosecuting the promoter of the scam.
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
of material fact, and factual inferences will be read in a manner
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