THOMSEN, Judge:
In this civil action brought by the Trustees of the Property of Penn Central Transportation Company (PC) against United States Railway Association (USRA) and Consolidated Rail Corporation (Conrail), PC seeks a declaratory judgment that Conrail is responsible for the payment of portions of various taxes and other charges which were assessed against PC by several state authorities, based upon the gross revenues earned by PC from its intrastate operations...
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