Per Curiam.
We agree with the commissioner on both issues under appeal and reverse the decision of the BTA.
Former R.C. 5733.051(A)(2) and (8), for the pertinent years, provided:
"Net income of a corporation subject to the tax imposed by this chapter shall be allocated and apportioned to this state as follows:
"* * *
"(2) Net rents and royalties from tangible personal property, to the extent such property is utilized in this...
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