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MEMORANDUM OPINION
JACOBS, Judge: This case is before the Court on the motion of
Erna C. Scrimshaw (hereinafter petitioner when used in the
singular) for leave to file a motion to vacate decision entered on
July 26, 1991. Petitioner's motion to vacate decision is based
upon the theory that the stipulated decision entered in
petitioners' case was the result of fraud on the Court because her
signature on the decision document is a forgery. In her motion,
petitioner requests, among other things, that she be allowed to
amend the pleadings in order to raise the defense of "innocent
spouse". Respondent filed a response in opposition to petitioner's
motion. As explained below, we shall deny petitioner's motion.
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the matter under consideration.
All Rule references are to the Tax Court Rules of Practice and
Procedure.
Petitioner and George C. Scrimshaw (collectively referred to
as petitioners) were husband and wife and resided in Orinda,
California, at the time the petition was filed.
Background
Petitioners were married on September 14, 1957. Petitioner
worked as a registered nurse, and her husband was a physician. In
1962, after the birth of petitioners' first child, petitioner
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