- 6 -
Respondent also submitted a reply memorandum in opposition to the
estate’s motion for partial summary judgment.
Discussion
Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials. Fla. Peach Corp. v.
Commissioner, 90 T.C. 678, 681 (1988). Either party may move for
summary judgment upon all or any part of the legal issues in
controversy. A decision may be rendered by way of summary
judgment 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);
Naftel v. Commissioner, 85 T.C. 527, 529 (1985). This case is
ripe for summary judgment because both parties agree on all of
the relevant facts and a decision may be rendered as a matter of
law.
Section 2001 imposes a Federal tax “on the transfer of the
taxable estate of every decedent who is a citizen or resident of
the United States.” A deceased taxpayer’s gross estate includes
the fair market value of any interest the decedent held in
property. See secs. 2031(a), 2033; sec. 20.2031-1(b), Estate Tax
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