- 5 -
We conclude that we do not have jurisdiction over the
instant case. That is because the parties agree that the respec-
tive liabilities for tax for the taxable years 1997, 2000, and
2003 did not remain unpaid as of December 20, 2006, the date of
the enactment of the Act.
To reflect the foregoing,
An order granting respondent’s
motion to dismiss for lack of
jurisdiction will be entered.
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Last modified: May 25, 2011