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In 1998, petitioner received $68,532 from Focaltron
Corporation as nonemployee compensation and $32 from Wells Fargo
Bank as interest income.
Petitioner admits that he did not file a Federal income tax
return for tax year 1998 and did not make any payments for tax
year 1998.
Discussion
I. Motion for 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 who 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, 537-538 (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.
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