MEMORANDUM OPINION AND ORDER
WEINER, Judge.
The above-captioned cause of action was instituted by the State of New Jersey, its Treasurer, Tax Director and Budget Director on March 1, 1983 against the Consolidated Rail Corporation ("Conrail") and the United States of America. The State is seeking monetary, declaratory and injunctive relief for unpaid taxes imposed against Conrail pursuant to the New Jersey Railroad Tax Act, N.J.S.A. 54:29A-1, et seq.,...
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