Devery W. Hennard - Page 5

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               Summary judgment is intended to expedite litigation and                
          avoid unnecessary and expensive trials.  Fla. Peach Corp. v.                
          Commissioner, 90 T.C. 678, 681 (1988).  Summary judgment may be             
          granted where there is no genuine issue of material fact and a              
          decision may be rendered as a matter of law.  Rule 121(a) and               
          (b).  The moving party bears the burden proving that there is no            
          genuine issue of material fact, and factual inferences are viewed           
          in a light most favorable to the nonmoving party.  Craig v.                 
          Commissioner, 119 T.C. 252, 260 (2002); Dahlstrom v.                        
          Commissioner, 85 T.C. 812, 821 (1985); Jacklin v. Commissioner,             
          79 T.C. 340, 344 (1982).  The party opposing summary judgment               
          must set forth specific facts which show that a question of                 
          genuine material fact exists and may not rely merely on                     
          allegations or denials in the pleadings.  Grant Creek Water                 
          Works, Ltd. v. Commissioner, 91 T.C. 322, 325 (1988); Casanova              
          Co. v. Commissioner, 87 T.C. 214, 217 (1986).                               
               Petitioner has not set forth specific facts showing a                  
          genuine issue of material fact exists.  Petitioner ignored our              
          order to file an answer to respondent’s motion and failed to                
          appear at trial.  The petition contains nothing but nonsensical             
          tax protester arguments that are frivolous, and we do not address           
          petitioner’s arguments with somber reasoning and copious                    
          citations of precedent, as to do so might suggest that                      

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