- 13 - OPINION I. Preliminary Matters A. Petitioner’s Motions for Partial Summary Judgment and To Reopen the Record On brief, petitioner states that he reasserts and resubmits his previous motions for partial summary judgment and to reopen the record. These requests were denied by means of the Court’s August 4, 2003, order, and we decline to modify that disposition for the reasons described briefly below. Summary judgment is intended to expedite litigation and to avoid unnecessary and expensive trials. FPL Group, Inc. v. Commissioner, 116 T.C. 73, 74 (2001); Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988). Rule 121(a) allows a party to move “for a summary adjudication in the moving party’s favor upon all or any part of the legal issues in controversy.” Rule 121(b) directs that a decision on such a motion shall 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.” Petitioner’s motion for summary judgment asked for “an order adjudicating that a taxpayer’s receipt of a W-2 form does not, without more, preclude deductibility of legitimate businessPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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