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that, even if they were, petitioners have not shown that they are
entitled to the relief that they seek under that rule. We agree
with respondent.
Based on our review of the entire record before us, we find
that petitioners have failed to show that the decision entered in
this case is the result of fraud on the Court or any other
situation that warrants our exercise of our discretion under Rule
162 to grant petitioners' motion.
We also reject petitioners' argument relating to rule 60(b)
of the Federal Rules of Civil Procedure. Assuming arguendo that
all of the reasons specified in that rule were criteria that this
Court may apply in deciding whether petitioners' motion should be
granted, on the record before us, petitioners have failed to
establish that they are entitled to relief under rule 60(b) of
the Federal Rules of Civil Procedure. In this connection, the
record does not establish as facts petitioners' contentions that
they did not have information with respect to certain claimed
interest expense deductions for their taxable years 1981, 1982,
and 1983 until March 1997, when respondent provided petitioners
with final interest calculations, or that they could not have
discovered such information prior to that time. Nor does the
record show that petitioners could not have included as part of
the stipulation of settlement with respondent provisions relating
to whether they are entitled to interest expense deductions for
those taxable years.
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