- 30 -                                         
          Commissioner, T.C. Memo. 1993-381; see also Heim v. Commissioner,           
          872 F.2d 245, 249 (8th Cir. 1989), affg. an order of the Court;             
          Toscano v. Commissioner, 441 F.2d at 933; Kenner v. Commissioner,           
          supra at 691-692; DiSanza v. Commissioner, supra; Pulitzer v.               
          Commissioner, T.C. Memo. 1987-408.                                          
               The Court is satisfied that neither Mr. Young, Mr.                     
          Pasternak, nor any other party involved in the Pop Phonomasters             
          litigation, made any deliberate attempt to deny Mr. or Mrs.                 
          Dornbrock or the Estate of Roger W. Dornbrock, deceased, Maryn J.           
          Dornbrock, personal representative, their right to be heard by              
          this Court.  Mrs. Dornbrock has failed to show that any of Mr.              
          Young's actions in this case involved the "evil intent, deceit or           
          collusion which have marked those cases where final verdicts have           
          been set aside."  See Senate Realty Corp. v. Commissioner, 511              
          F.2d at 933.  Mrs. Dornbrock has not convinced us that a fraud              
          was perpetrated on this Court in the entry of the decision of               
          this case on December 23, 1993, as to Maryn J. Dornbrock or the             
          Estate of Roger W. Dornbrock, deceased, Maryn J. Dornbrock,                 
          personal representative.  Therefore, Mrs. Dornbrock's motion for            
          leave to file a motion to vacate or revise decision will be                 
          denied.                                                                     
          An appropriate order                                                        
          will be issued.                                                             
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