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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 may be
granted where there is no genuine issue of material fact and
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 there is no genuine issue of material fact;
factual inferences will be made most favorably to the party
opposing summary judgment. Dahlstrom v. Commissioner, 85 T.C.
812, 821 (1985); Jacklin v. Commissioner, 79 T.C. 340, 344
(1982). When, however, a motion for summary judgment is made and
properly supported, the party opposing summary judgment may not
rely on mere allegations or on denials of the movant's pleadings
but must set forth specific facts in dispute and show that there
is a genuine issue for trial. Rule 121(d).
As discussed below, we conclude that no material fact is in
dispute and that respondent is entitled to summary judgment as a
matter of law. Accordingly, we shall grant respondent’s motion.
Background
For each of her taxable years 1995, 1996, and 1997,
petitioner timely filed a Federal income tax return claiming
head-of-household filing status, dependency deductions under
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