District Court, E.D. Virginia December 28, 1998, CIV.A. 3:98cv370 (Ranger Fuel Corp. v. United States)

DECLARATORY JUDGMENT AND ORDER

WILLIAMS, Senior District Judge.

This matter is before the Court on plaintiffs’ motion for summary judgment. Plaintiffs’ motion for summary judgment is GRANTED in part and CONDITIONALLY GRANTED in part. For the reasons stated in the accompanying Memorandum Opinion, the Court hereby DECLARES Section 4121 of the Internal Revenue Code, 26 U.S.C.