TROOP, P. J.
A notice of appeal, filed December 26, 1973, indicates an appeal from a judgment of the Court of Common Pleas of this county entered November 28, 1973. The trial court granted a summary judgment in favor of the defendants, at the plaintiffs' costs. The trial court summarizes the action of the plaintiffs and the basis of the result reached in its formal entry, as follows:
"Plaintiffs challenge the validity of the Ohio Income
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