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Petitioners did not file a notice of appeal or a timely
motion to vacate or revise our decision which was entered on
July 22, 1993. Accordingly, our decision became final on
October 20, 1993. See secs. 7459(c), 7481(a)(1). Once a
decision becomes final, our jurisdiction to vacate it is
restricted. Abatti v. Commissioner, 859 F.2d 115, 117 (9th Cir.
1988), affg. 86 T.C. 1319 (1986); Lasky v. Commissioner, 235 F.2d
97, 100 (9th Cir. 1957), affg. 22 T.C. 13 (1954). We shall
vacate a final decision only in certain limited cases. For
example, this Court and some Courts of Appeals have ruled that we
may vacate a final decision if it is shown to be void, or a legal
nullity, for lack of jurisdiction over either the subject matter
or the party, see Billingsley v. Commissioner, 868 F.2d 1081,
1084-1085 (9th Cir. 1989); Abeles v. Commissioner, 90 T.C. 103,
105-106 (1988); Brannon's of Shawnee, Inc. v. Commissioner, 69
T.C. 999, 1002 (1978), or if it was obtained through fraud on the
Court, see Abatti v. Commissioner, supra; Senate Realty Corp. v.
Commissioner, 511 F.2d 929, 931 n.1 (2d Cir. 1975); Stickler v.
Commissioner, 464 F.2d 368, 370 (3d Cir. 1972); Casey v.
Commissioner, T.C. Memo. 1992-672. The Court of Appeals for the
Fifth Circuit also has indicated that we have the power to vacate
a final decision which is based on a mutual mistake of fact.
See La Floridienne J. Buttgenbach & Co. v. Commissioner, 63 F.2d
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