Jerry and Patricia A. Dixon, et al. - Page 16

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                                     Discussion                                       
               In their motion for reconsideration, petitioners ask the               
          Court to investigate and impose sanctions on respondent for                 
          alleged misconduct that occurred after the trial of the test                
          cases.                                                                      
               Petitioners argue that there is substantial newly discovered           
          evidence that respondent’s management made misrepresentations to            
          cover up the extent of the fraud of respondent’s trial attorneys            
          and to distort the facts in pleadings filed with this Court in              
          order to reduce the Government’s monetary exposure and contain              
          respondent’s public embarrassment and accountability.                       
          Petitioners ask the Court to conduct a further inquiry into                 
          respondent’s alleged coverup misconduct and to impose additional            
          sanctions on respondent for that misconduct.                                
               Respondent counters that, upon receiving the mandate of an             
          appellate court, the lower court cannot vary it or examine it for           
          any purpose other than execution, and that the Tax Court has                
          fully complied in Dixon VI with the mandate of the Court of                 
          Appeals in Dixon V.  We agree with respondent.                              
               The Courts of Appeals have exclusive jurisdiction to review            
          the decisions of the Tax Court in the same manner and to the same           
          extent as decisions of the District Courts in civil actions tried           
          without a jury.  Sec. 7482(a)(1).  Upon such review, the Courts             
          of Appeals “have power to affirm or, if the decision of the Tax             






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