Robert Lee, Jr. - Page 6

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          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           
          most favorable to the party opposing summary judgment.  Dahlstrom           
          v. Commissioner, 85 T.C. 812, 821 (1985); Jacklin v.                        
          Commissioner, 79 T.C. 340, 344 (1982).  Based on our review of              
          the record, we are satisfied that there is no genuine issue as to           
          any material fact and that respondent is entitled to judgment as            
          a matter of law.                                                            
               Petitioner’s conduct in his earlier deficiency case at                 
          docket No. 6655-00, coupled with the arguments that he made in              
          his request for collection due process hearing, clearly                     
          demonstrate that petitioner initiated the collection review                 
          procedures set forth in section 6330 solely for the purpose of              
          delay.  As discussed below, the arguments that petitioner                   
          included in his request for a collection due process hearing have           
          no merit.  Moreover, petitioner ignored the opportunity that the            
          Court extended to him to file an amended petition setting forth a           

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