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MEMORANDUM OPINION
BEGHE, Judge: This matter is before the Court on
petitioners’ motions for leave to file motions to vacate
stipulated decisions entered more than 12 years ago in the above-
numbered dockets. The motions for leave, which have been filed,
are accompanied by motions to vacate, which have been lodged.
The issue presented by the lodged motions is whether stipulated
decisions previously entered should be vacated because of fraud
on the Court. We have followed our practice of examining the
merits of the lodged motions in deciding whether to grant leave
to file them.2 We decide that the motions for leave to file
motions to vacate should be denied.
Background
Petitioners’ motions have been made in the context of the
difficult, protracted, and ongoing litigation commencing with
Dixon v. Commissioner, T.C. Memo. 1999-614 (Dixon II),3 revd. and
remanded sub nom. DuFresne v. Commissioner, 26 F.3d 105 (9th Cir.
1994), on remand Dixon v. Commissioner, T.C. Memo. 1999-101
(Dixon III), supplemented by T.C. Memo. 2000-116 (Dixon IV),
revd. and remanded 316 F.3d 1041, 1047 (9th Cir. 2003) (Dixon V).
For purposes of these motions, we take judicial notice of our
2See infra note 28.
3See infra note 10 regarding Dixon I.
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