By Rusudan Shervashidze and Stanley Ruchelman ( May 14, 2018, 4:01 PM EDT) -- In the procedural maze that leads to a trial in the U.S. Tax Court, motion practice is an important part of tailoring issues presented to the court. In particular, motions to grant summary judgment are often filed by the IRS to preclude a full trial. According to Rule 121(a) of the U.S. Tax Court rules of practice and procedure, either the taxpayer or the IRS may submit a motion for summary judgment in its favor regarding all or any part of the legal issues in controversy. The motion is granted and an order is issued if the party requesting summary judgment shows that no genuine dispute exists as to any material fact and the moving party is entitled to a favorable decision based solely on the law and the undisputed facts. While the reasoning of the court in granting the motion is not binding, it is informative of the state of the law....