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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 business
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