COOK, J.
Ohio corporations calculate their franchise tax on both a net worth basis and a net income basis and pay whichever produces the greater tax. R.C. 5733.06. In this case, the relevant calculation is net income. The initial base for the net income tax is federal taxable income before net operating loss and special deductions. R.C. 5733.04(I). From that figure, Ohio corporations are permitted to "[a]dd any loss or deduct any gain resulting from the sale, exchange...
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