RUSSELL, Justice.
The dispositive question in this appeal is whether the District of Columbia's tax on the net income of unincorporated businesses, D.C.Code Ann. § 47-1808.1, et seq. (1981), (the UB tax) is an income tax or a franchise tax. If it is an income tax, a Virginia resident, who does business in the District of Columbia and pays the tax there, is entitled to credit against his Virginia income taxes for the amount paid to the District of Columbia...
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