Annamalai v. Comm'r of Internal Revenue

*531 Before us today is an appellate jurisdictional issue of first impression. Under Federal Rule of Appellate Procedure 13, the statutory 90-day window to appeal a Tax Court decision to our court runs from either: 1) the entry of the Tax Court decision being appealed or 2) if a party moves to vacate or revise the Tax Court's decision, from the entry of the Tax Court's ruling on that motion to vacate or revise the decision. The question before us is whether a party may file successive motions to vacate or revise with the effect of extending the time to appeal into perpetuity. We hold that…