HERNDON, J.
This action was brought by plaintiffs, hereinafter called the "taxpayers," to recover income taxes paid under protest to the State of California following disallowance by the Franchise Tax Board, hereinafter called the "Board," of credit for certain Canadian income taxes paid by the taxpayers. The trial court decided the legal issues in accordance with the taxpayers' contentions and rendered judgment accordingly. The Board brings this appeal.
The...
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