OPINION
WARRINER, District Judge.
Presently before the Court is defendant Department of Taxation, Commonwealth of Virginia's ripe motion for judgment on the pleadings, plaintiff Richmond, Fredericksburg & Potomac Railroad Company's motion for summary judgment, and defendant Department of Taxation's cross-motion for summary judgment. The motions have been thoroughly briefed and oral argument has been heard. The matter is, therefore, ripe for adjudication...
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