Ella Louise Wooten - Page 2

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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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