Burgess J.W. Raby & William L. Raby have published Summary Judgment vs. Declaratory Judgment, also available on the Tax Analysts web site as Doc 2005-10179, 2005 TNT 90-54.  Here is the abstract:

This article discusses two procedural approaches in resolving tax controversies that are foreign to the experience of the average nonattorney tax practitioner and even to many attorney tax practitioners. They are not alternatives but are separate and different approaches to disparate situations. We are discussing them in one article because recent cases illustrate how they work and because we have discovered in seminars that they sometimes seem to create confusion among nonlawyer tax practitioners.