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the motion. Toscano v. Commissioner, 441 F.2d 930, 932 (9th Cir.
1971), vacating 52 T.C. 295 (1969). On the other hand, a
"decision" entered in a case where this Court never acquired
jurisdiction over a taxpayer is a legal nullity, and, therefore,
not a "decision", as to that taxpayer. Billingsley v.
Commissioner, 868 F.2d 1081, 1085 (9th Cir. 1989). Accordingly,
a judgment void for lack of jurisdiction may be vacated at any
time. Billingsley v. Commissioner, supra at 1084; Brannon's of
Shawnee, Inc. v. Commissioner, 71 T.C. 108, 111-112 (1978). The
motion filed in this case is directed to the latter situation.
Our jurisdiction depends on a timely filed petition. Levitt
v. Commissioner, 97 T.C. 437, 441 (1991). When a taxpayer files
a timely petition, this Court's jurisdiction is invoked and
remains unimpaired until we decide the controversy. Dorl v.
Commissioner, 57 T.C. 720, 722 (1972); Main-Hammond Land Trust v.
Commissioner, 17 T.C. 942, 956 (1951). However, when an
individual fails to sign the petition or to ratify a petition and
does not intend to become a party to the litigation, this Court
acquires no jurisdiction over that individual. Levitt v.
Commissioner, 97 T.C. at 441. Ratification requires a showing of
proper authorization by the signing party to act on behalf of the
non-signing party. Id.
When a petition is filed by an attorney on behalf of a
taxpayer the issue is whether that individual authorized the
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