-10- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011