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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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