Alan Horowitz was quoted regarding a case in which the taxpayer has sought Supreme Court review that involves the applicability to dial-up Internet service of the 1965 excise tax on local telephone service. Horowitz, who filed amicus briefs on behalf of the U.S. Telecom Association supporting WorldCom's petition for certiorari in the Supreme Court and its petition for rehearing in the Second Circuit, said that taxpayers are concerned the court's ruling could invite the IRS to be more aggressive in applying the excise tax other emerging communications services. "Related to that, due to the way in which this tax is set up, service providers are responsible for collecting the tax from customers, and in the absence of clear guidance on how the law is imposed, they may have to guess and impose the tax when it's not actually necessary," Horowitz said. "The law was a lot clearer before this case came out, and now it's a mess."