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by the Executive Branch, powers which included no incidental
principles of equity. Commissioner v. Gooch Milling & Elevator
Co., 320 U.S. 418 (1943); Old Colony Trust Co. v. Commissioner,
279 U.S. 716, 725 (1929). The fact that these predecessors were
executive agencies and not courts of law made them fundamentally
different from the District Courts. The fact that these
predecessors were executive agencies and not courts of law made
them fundamentally different from this Court.
C. Relevant Jurisprudence Concerning the Authority of This
Court’s Predecessors To Apply Rule 60(b)
Sections 7481 and 7483 generally provide that a decision of
this Court becomes “final” 90 days from the date that the
decision is entered, absent a timely filed notice of appeal. In
the case of an appeal, section 7481 provides similar time periods
as to each possibility related to the resolution of that appeal.
The vast preponderance of judicial jurisprudence compels the
conclusion that this Court’s predecessors had little, if any,
power to vacate a decision that had become “final” under sections
7481 and 7483 (or the predecessors thereof). The gist of this
jurisprudence was that these sections provided set rules on the
finality of a decision, R. Simpson & Co. v. Commissioner, 321
U.S. 225 (1944); Helvering v. N. Coal Co., 293 U.S. 191 (1934);
see also Lasky v. Commissioner, 352 U.S. 1027 (1957) (per curiam
opinion relying entirely upon R. Simpson & Co. v. Commissioner,
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