Per Curiam.
Ohio levies the franchise tax on foreign corporations for the privilege of doing business in Ohio, owning or using a part or all of its capital or property in Ohio, or holding a certificate authorizing it to do business in Ohio. R.C. 5733.01(A). Ohio levies the tax on the net worth or net income basis, whichever produces the greater tax. R.C. 5733.06. This appeal concerns the net income basis.
Ohio allocates some income entirely to Ohio...
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