dissenting. I must dissent in that, in my view, the Board of Tax Appeals reasonably found that the amounts involved here were received for technical services, and were derived from sources outside the United States, and as such were deductible from net income pursuant to R. C. 5733.04(I)(2).
I would affirm the order of the Board of Tax Appeals.
Hofstetter, J., concurs in the foregoing dissenting opinion.