Catherine Beverly - Page 2

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               Catherine Beverly, pro se.                                             
               Karen Baker and Michael W. Bitner, for respondent.                     


                                 MEMORANDUM OPINION                                   
               PANUTHOS, Chief Special Trial Judge:  This collection review           
          case is before the Court on respondent’s Motion for Summary                 
          Judgment, as supplemented, filed pursuant to Rule 121.1                     
          Summary judgment is intended to expedite litigation and avoid               
          unnecessary and expensive trials.  Fla. Peach Corp. v.                      
          Commissioner, 90 T.C. 678, 681 (1988); Naftel v. Commissioner, 85           
          T.C. 527 (1985).  Summary judgment may be granted with respect to           
          all or any part of the legal issues in controversy “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.”               
          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).  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.             


               1  Unless otherwise indicated, section references are to the           
          Internal Revenue Code, as amended.  Rule references are to the              
          Tax Court Rules of Practice and Procedure.                                  




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