BRAY, P.J.
Plaintiffs appeal from a judgment in favor of defendant denying them a refund of personal income taxes.
QUESTIONS PRESENTED
1. Was the Canadian income tax paid by California residents on corporate dividends a "net income tax" under section 18001 of the Revenue and Taxation Code (formerly § 17976)?
2. Is section 18001 unconstitutional?
RECORD
The facts were stipulated. Plaintiffs during the years 1949-1953...
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