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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). 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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Last modified: May 25, 2011