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sign the decision document. They further allege that their
attorney, Mr. Griffin, did not have the authority to sign the
decision. Petitioners base their argument of lack of authority
of their attorney on the fact that a few days earlier, on
December 29, 1993, petitioners executed IRS Form 2848, Power of
Attorney and Declaration of Representative, in which they revoked
all previous powers of attorney and designated petitioner Juanita
D. Murdock as their agent and representative for petitioners'
1988 and 1989 tax years. Thus, petitioners contend Mr. Griffin
no longer had any authority to represent petitioners in this
case, and, since petitioner Juanita D. Murdock was not present at
the conference with counsel for respondent on January 5, 1994,
the stipulated decision signed on their behalf by Mr. Griffin is
invalid. Respondent objects to petitioners' motion.
Sections 7481 and 7483 provide generally that a decision of
this Court becomes final, in the absence of a timely filed notice
of appeal, 90 days from the date the decision is entered. As a
general rule, this Court is without jurisdiction to vacate a
decision after the decision becomes final.
Petitioners contend that our final decision herein should be
vacated on the ground that it was entered as a result of fraud on
the Court. Petitioners, therefore, must establish that there was
fraud on the Court in the entry of the decision on January 11,
1994, based on the conference of January 5, 1994. The burden of
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