Harris Levin and Gayle Levin - Page 5

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          Other Income was issued by the IRS to the Los Angeles Unified               
          School District.  The notice stated, in part:  "This levy is                
          attached to the taxpayer's retirement pension only.  It should              
          not be attached to the taxpayer's wages."                                   
               In 1993, Ms. Levin consulted new counsel in relation to                
          attempts by the IRS to collect petitioners' tax liabilities from            
          Ms. Levin's interest in the teachers' retirement fund.  Counsel             
          attempted unsuccessfully to secure administratively "innocent               
          spouse" relief for Ms. Levin from the IRS.  In 1995, counsel                
          decided that Ms. Levin also had a statute of limitations defense            
          to the tax liability because she had not signed the Form 2848,              
          Power of Attorney, or otherwise agreed to the extension of the              
          period of limitations.  On September 28, 1995, Ms. Levin's Motion           
          for Leave to File Motion to Vacate Decision Out of Time was filed           
          and an accompanying Motion to Vacate Decision was lodged.  The              
          motion to vacate is made on the grounds that the decision was               
          entered as a result of a fraud upon the Court and without                   
          personal jurisdiction over Ms. Levin.  Ms. Levin seeks to vacate            
          the decision only as to 1980.                                               
               Because the decision entered in this case has long been                
          final, to be successful in her pending motion, Ms. Levin must               
          establish that the decision was secured either by a fraud on the            
          Court or that the Court lacked jurisdiction over her.  See,                 

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