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On July 17, 2006, while residing in Justin, Texas,
petitioner filed his petition. In the petition, the assignment
of error states in its entirety:
Set aside the notice of determination on the grounds
the Appeals Officer failed to verify the requirements
of all applicable law or administrative procedure were
met in determining the liability, thus creating an
abuse of discretion. Specifically, Respondent ignored
the requirements at IRC 6012 & 151(d) and the Paperwork
Reduction Act of 1995. Petitioner has not been
presented with a proper information collection request
displaying a currently valid OMB control number, and
the exemption amount is unspecified in law. There are
multiple violations of the 1995 PRA bearing upon the
making of a return, and Respondent ignores the 1995 Act
while adhering to the 1980 Act.
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 any material fact, and
a decision may be rendered as a matter of law. Rule 121(a) and
(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 bears
the burden of proving that there is no genuine issue of material
fact, and factual inferences will be read in a manner most
favorable to the party opposing summary judgment. Dahlstrom v.
Commissioner, 85 T.C. 812, 821 (1985); Jacklin v. Commissioner,
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