MURPHY, Chief Judge.
The question presented is whether, under Maryland's income tax statutes, out-of-state losses incurred by a multi-state corporation reporting no federal taxable income may offset in-state capital gains allocable to this State under Maryland Code (1957, 1980 Repl.Vol.), Article 81, § 316(b)(3).
I.
Maryland's corporate income tax was originally enacted in 1937.
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