Stephen C. Gara (Old Dominion University, College of Business & Public Administration) has published Challenging the Finality of Tax Court Judgments: When Is Final Not Really Final?, 20 Akron Tax J. 35 (2005). Here is part of the Introduction:

The present article reviews this statutory finality rule and the development of equitable exceptions to it, particularly the application of the fraud upon the court doctrine. The next section provides an overview of the Tax Court, followed by a discussion of judgment finality and § 7481. Part four discusses the fraud upon the court doctrine and its applicability in reviewing final judgments. The development of other exceptions to § 7481 is analyzed next. The article concludes with an assessment of the current state of the Tax Court’s authority to make exceptions to § 7481.