Thomas J. & Gisella Sabath - Page 10

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          respondent.  Instead, petitioner specifically challenges the                
          amount of the liability.  The fact that the amount of his unpaid            
          tax liability is no longer in dispute on account of his                     
          settlement is of no consequence to us.  Our ability to decide               
          petitioner’s underlying tax liability “‘depends on the state of             
          things at the time of the action brought,’”  Keene Corp. v.                 
          United States, 508 U.S. 200, 208 (1993) (quoting Mollan v.                  
          Torrance, 22 U.S. (9 Wheat.) 537, 539 (1824)), and not on the               
          state of things when we enter our decision in the action.                   
               Accordingly,                                                           
                                        An appropriate order will be                  
                                   issued.                                            


























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