DORAN, J.
The within appeal is taken from a judgment in favor of the respondent executrix, for refund of state income taxes, paid under protest, for the years 1938, 1939, 1940 and 1941. The case involves two different claims for refund, namely, credit on the California tax of a 5 per cent Canadian income tax on dividends paid by a Canadian corporation which neither did business in, nor had an office or agent in California; and a deduction for accounting expenses incurred...
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