BATCHELDER, Circuit Judge.
The United States appeals the district court's order granting judgment in favor of Plaintiffs-Appellees FedEx Corp. and subsidiaries ("FedEx") for overpayment of taxes in the amount of $66,474,287.10 plus interest thereon. FedEx, a common carrier, paid $70,000,000 in taxes and accrued interest pursuant to an Internal Revenue Service determination that it was required to capitalize, rather than currently deduct, expenses attributable to off...
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