KATZMANN, Circuit Judge:
This case calls on us to decide if the bankrupt telecommunications company WorldCom must pay federal excise taxes on the purchase of a telecommunications service that connected people using dial-up modems to the Internet. Appellant, the Internal Revenue Service ("IRS"), appeals from a judgment of the United States District Court for the Southern District of New York (Forrest, J.), which upheld the decision of the Bankruptcy Court (Gonzalez...
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