are not made moot by the law of the case doctrine because the later MOA does not encompass the entire project. The law of the case doctrine “expresses the practice of courts generally to refuse to reopen what has been decided, not a limit to their power.” Messinger v. Anderson, 225 U.S. 436, 443, 32 S.Ct. 739, 56 L.Ed. 1152 (1912). The doctrine applies not only to issues decided explicitly, but also to everything decided “by necessary implication.” Browning v. Navarro, 887 F.2d 553, 556 (5th Cir.1989). We reject this argument for the reasons discussed supra; the second, final MOA is a comprehensive document and supercedes the original. Corrective action by an agency can moot an issue. See, e.g., Commissioner v. Shapiro, 424 U.S. 614, 622-23 n. 7, 96 S.Ct. 1062, 47 L.Ed.2d 278 (1976) (<HOLDING>). Other circuits have found that subsequent
holding service not defective where debtor had failed to notify court of his new address holding that proper service of new notice of deficiency and new notices of levy moots question as to whether prior actions were procedurally defective holding invalid procedurally defective interim regulations that were issued without notice and comment and in the absence of good cause holding that a second deficiency notice issued for a taxable year was valid where it determined a deficiency in a different type of tax than did the earlier deficiency notice holding that where notice of deficiency fails adequately to describe the basis on which the commissioner relies for his deficiency determination burden shifts to the commissioner to prove the accuracy of the deficiency determination