MCI Communications Corp. v. United States

OPINION

STANLEY S. HARRIS, District Judge.

Before the Court are the parties’ cross-motions for summary judgment, corresponding oppositions, plaintiffs’ reply, and plaintiffs’ notice of recent authority. After careful consideration of the entire record, the Court denies plaintiffs’ motion for summary judgment and grants defendant’s motion for summary judgment. Although “[fjindings of fact and conclusions of law are unnecessary on decisions of motions under Rule ... 56,” the Court nevertheless sets forth its analysis. See Fed.R.Civ.P. 52(a).

BACKGROUND

Prior to 1986, when the Tax Reform Act of…