- 9 -
including the Modoc property. Defendant has demon-
strated that * * * [petitioners] and * * * [the founda-
tion] share a 'close relationship'. * * * [Petitioners]
have continued to use the property despite the transfer
of the property among different entities. * * * [Peti-
tioners] continue to pay the bills associated with the
maintenance of the property. It is clear from the
facts that * * * [the foundation] is * * * [petition-
ers'] nominee. [Citations omitted.]
Discussion
The Court's decision in this case was entered on October 16,
1995. No notice of appeal or timely motion to vacate or revise
the decision was filed in this case, see sec. 7483; Rule 162, and
the decision herein became final on January 15, 1996, see sec.
7481(a)(1); Fed. R. App. P. 13(a).
Petitioners' motion was filed on December 2, 1997, over two
years after the Court entered the decision in this case. Once a
decision becomes final, the Court may vacate it only in narrowly
circumscribed situations, such as where the decision was obtained
through fraud on the Court, see Abatti v. Commissioner, 859 F.2d
115, 118 (9th Cir. 1988), affg. 86 T.C. 1319 (1986); Senate
Realty Corp. v. Commissioner, 511 F.2d 929, 931 n.1 (2d Cir.
1975), or where the decision is void or a legal nullity for lack
of this Court's jurisdiction over either the subject matter or
the party, see Billingsley v. Commissioner, 868 F.2d 1081, 1084-
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