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pursue collection alternatives or an offer in compromise.
Respondent contends that petitioner’s March 4, 2002, letter was
not received and petitioner did not make an offer in compromise
or propose collection alternatives.
“Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials.” Florida Peach Corp. v.
Commissioner, 90 T.C. 678, 681 (1988). A motion for summary
judgment may be granted where there is no dispute as to a
material fact and a decision may be rendered as a matter of law.
See Rule 121(a) and (b).1 The moving party bears the burden of
proving that there is no genuine issue of material fact, and
factual inferences are viewed in a manner most favorable to the
other party. See Craig v. Commissioner, 119 T.C. 252, 260 (2002)
(citing Dahlstrom v. Commissioner, 85 T.C. 812, 821 (1985)). The
party opposing summary judgment must set forth specific facts
which show that a question of genuine material fact exists and
may not rely merely on allegations or denials in his pleadings.
1Rule 121(b) provides:
A decision shall thereafter be rendered 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. * * *
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