Per Curiam.
At issue in this case is whether the dividends received by a taxpayer from a domestic international sales corporation should be subject to apportionment to Ohio for the purposes of the franchise tax. For the period in question, the pertinent language of R.C. 5733.051 provided for the allocation or apportionment of net income as follows:
"(A) Net income of a corporation subject to the tax imposed by this chapter shall be allocated and apportioned...
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