TAYLOR, J.
Plaintiffs (hereafter taxpayers) appeal from a judgment in favor of defendant, Franchise Tax Board (hereafter Board) denying them a refund of personal income taxes paid under protest to the State of California, following disallowance by the Board of a deduction or a tax credit for certain Japanese income taxes. The taxpayers contend that sections 17204 and 18001 of the Revenue and Taxation Code, which respectively deny the deduction and credit, are unconstitutional...
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