Jesse M. and Lura L. Lewis - Page 3

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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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