Glenn Broderick - Page 6




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          affidavit supplementing his opposition disputed any of the                  
          material facts alleged in respondent’s summary judgment motion              
          and supporting materials.                                                   
               On April 17, 2006, a hearing was held on respondent’s                  
          motion.  Petitioner did not appear.                                         
                                     Discussion                                       
          A.  Summary Disposition                                                     
               Summary judgment is a procedure designed to expedite                   
          litigation and avoid unnecessary, time-consuming, and expensive             
          trials.  Fla. Peach Corp. v. Commissioner, 90 T.C. 678, 681                 
          (1988).  Summary judgment may be granted with respect to all or             
          any part of the legal issues presented “if the pleadings, answers           
          to interrogatories, depositions, admissions, and any other                  
          acceptable materials, together with the affidavits, if any, show            
          that there is no genuine issue as to any material fact and that 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).  The facts material to the           
          Court’s disposition of the motion for summary judgment are stated           







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