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notified the Court of a change of address. Respondent does
not seek dismissal of the case for failure to prosecute.
Discussion
The purpose of summary judgment is to expedite
litigation and avoid unnecessary and expensive trials.
See, e.g., Keene v. Commissioner, 121 T.C. 8, 14 (2003);
Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681 (1988).
Generally, we grant summary judgment if the pleadings,
answers to interrogatories, depositions, admissions, and
any other acceptable materials show that there is no
genuine issue of any material fact and a decision may be
rendered as a matter of law. Rule 121(b); see 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, respondent in this case, bears the
burden of proving that there is no genuine issue of
material fact. Dahlstrom v. Commissioner, 85 T.C. 812, 821
(1985); Jacklin v. Commissioner, 79 T.C. 340, 344 (1982).
Factual inferences will be made in a manner most favorable
to the party opposing summary judgment, petitioner in this
case. Dahlstrom v. Commissioner, supra at 821.
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