Robert E. and Mary K. Adams - Page 3

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          Discussion                                                                  
          I.  Summary Judgment                                                        
               Rule 121(a) provides that either party may move for summary            
          judgment upon all or any part of the legal issues in controversy.           
          Summary judgment may be granted if it is demonstrated that no               
          genuine issue exists as to any material fact and 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).  As the party that moved for summary judgment,                  
          respondent has the burden of showing there is no genuine issue as           
          to any material fact and that he is entitled to judgment as a               
          matter of law.  Nis Family Trust v. Commissioner, 115 T.C. 523,             
          536, 538 (2000).                                                            
               We conclude that there is no genuine issue as to any                   
          material fact and that a decision may be rendered as a matter of            
          law.                                                                        
          II.  The Deficiency                                                         
               Section 61 defines gross income as all income from whatever            
          source derived.  Gross income includes, among other things,                 
          compensation for services, interest, and pensions.  Sec. 61(a).             
               Petitioners admit that they received the income listed in              
          the notice of deficiency.  However, petitioners contend, inter              
          alia, that the earnings they derived are not income, that                   
          therefore they are not liable for taxes, and that income                    






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