PAUL W. BROWN, J.
R. C. 5733.04(I) provides that "net income" is basically the taxpayer's taxable income under the Internal Revenue Code with certain adjustments, one of which permits a taxpayer to:
"(2) Deduct any amount included in net income by application of section 78 or 951 of the Internal Revenue Code, amounts received for royalties, technical or other services derived from sources outside the United States, and dividends received...
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