- 13 -
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.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011