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  1. at 340 (quoting In re Johns-Manville Corp., 7 F.3d at 34 ). Thus, the relief sought was not only post-confirmation, but it was also post-emergent from the bankruptcy. In this case, although the declaratory relief was sought post-confirmation, it was sought during the administration of the Liquidating Plan pursuant to an amended confirmation plan. A-C had not yet attempted to use NOLs to reduce its tax liability, but was merely seeking to prevent disallowance should it do so in the future. at 812 (stating that “under the circumstances presented here, it would be improper for this Court to determine in advance the post-confirmation NOL tax rights of a former debtor who has not yet attempted to use its NOLs”). [2] Because the IRS did not cross-appeal, its arguments regarding case or controversy, lack of controversy under 28 U.