OPINION
TEITELBAUM, Chief Judge.
I. Factual Background
Jordan Lilienthal is an official court reporter for the United States District Court for the Western District of Pennsylvania. He was notified by the City of Pittsburgh that pursuant to the City of Pittsburgh Code of Ordinances, Title Two, Chapter 243, it intended to assess and collect a business privilege tax on the gross receipts from the sale of transcripts provided by Lilienthal...
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