Per Curiam.
The decision of the BTA is affirmed in part and reversed in part.
I
Losses arising from General Mill's federal tax benefit agreements are apportionable under R.C. 5733.051(H).
R.C. 5733.051 provides in part as follows:
"Net income of a corporation subject to the tax imposed by this chapter shall be allocated and apportioned to this state as follows:
"* * *
"(B) Net rents and royalties from tangible...
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