Mark A. and Juanita D. Murdock - Page 5

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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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