-3- Petitioner’s father died in 1999 owning two IRAs with Edward D. Jones & Co. Petitioner was a beneficiary of both IRAs in the event of his father’s death. No nondeductible contributions were made to either of the IRAs. In 1999, after the death of his father, petitioner received lump-sum distributions from the IRAs of $7,000 and $12,561. Petitioner reported the $7,000 distribution on his 1999 return but listed it as nontaxable. Petitioner did not report the $12,561 distribution on his 1999 return. After the requests for admissions were deemed admitted, respondent filed a motion for summary judgment seeking judgment in respondent’s favor on all issues. Petitioner filed a timely response stating only that he “respectfully OBJECTS to Respondent’s MOTION FOR SUMMARY JUDGMENT.” 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). The Court may grant summary judgment when there is no genuine issue of 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); Zaentz v. Commissioner, 90 T.C. 753, 754 (1988). Rule 121(d) states: When a motion for summary judgment is made and supported as provided in this Rule, an adverse partyPage: Previous 1 2 3 4 5 6 NextLast modified: March 27, 2008