Harris Levin and Gayle Levin - Page 13

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          Whether Ms. Levin's failure to ask for more details concerning              
          how the matter was being "taken care of" was due to indifference            
          or, as she suggests, to avoid angering Mr. Levin, she left to him           
          decisions to be made concerning handling of the tax dispute.                
          Ms. Levin has not suggested that she had any reason not to file a           
          petition.  None of the steps that he took was beyond the scope of           
          his implied authority.                                                      
               Upon consideration of the entire record, we conclude that              
          the steps taken by Mr. Levin to prosecute and resolve this case             
          were authorized by Ms. Levin.  She has not established any ground           
          for vacating the decision entered in 1989.                                  
                                                  Petitioner Gayle Levin's            
                                             Motion for Leave to File                 
                                             Motion to Vacate Decision Out            
                                             of Time will be denied.                  

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