Sharon E. Backstrom, Harold J. and Zelma G. Barbret, Virginia Boland, John A. and Theresa A. Cislaghi, Estate of Roger W. Dornbrock, Gary E. and Beverly G. Engel, Hermann K. and Helen W. Enzmann, - Page 13

                                       - 13 -                                         

               In support of her motion, Mrs. Dornbrock asserts that she              
          (1) had no specific knowledge of the tax deficiencies at issue              
          herein, (2) did not sign the petition, (3) did not know Mr.                 
          Young, (4) did not personally authorize Mr. Young to file a                 
          petition on her behalf, (5) never received any communication from           
          Mr. Young regarding this case, (6) never received a bill from Mr.           
          Young for services rendered in this case, and (7) did not                   
          personally authorize Mr. Young to enter into a settlement                   
          agreement on her behalf or on behalf of her husband's estate.               
               Rule 162 provides that a motion to vacate shall be filed               
          within 30 days after a decision has been entered, unless the                
          Court shall otherwise permit.  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.  Toscano v. Commissioner, 441 F.2d 930, 932 (9th             
          Cir. 1971), vacating 52 T.C. 295 (1969).  However, a decision               
          entered in a case where this Court never acquired jurisdiction              
          over a taxpayer is a legal nullity and is, 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.               





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