Champion Spark Plug Co. v. Lindley

R. C. 5733.04(1) provides that net income for purposes of the Ohio corporate franchise tax generally consists of the taxpayer’s income which must be included under the Internal Revenue Code, subject to several adjustments. The adjustment which the parties agree is determinative in this appeal is contained in R. C. 5733.04(I)(2), which provides:

“Deduct any amount included in net income by application of section 78 or 951 of the Internal Revenue Code, amounts received for royalties, technical or other services derived from sources outside the United States, and dividends received from a…