Per Curiam.
R.C. 5747.01(A), during the audit period, defined "adjusted gross income," on which the Ohio income tax is levied (see R.C. 5747.02), as follows:
"`Adjusted gross income' means adjusted gross income as that term is defined and used in the Internal Revenue Code * * *, and excludes any amounts of income included in adjusted gross income by reason of Subchapter S, Chapter 1, Subtitle A, of the Internal Revenue Code, 26 U.S.C. 1371. * * *"<...
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