Per Curiam.
The primary issue for consideration in this cause is whether the Ohio personal income tax levied in R. C. 5747 et seq., which took effect January 1, 1972, was applied retroactively in this instance so as to violate Section 28 of Article II of the Constitution of Ohio and the Due Process Clause of the Fourteenth Amendment.
R. C. 5747.02 provides that the state personal income tax shall be measured by "adjusted gross income * * *."...
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