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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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