In Beamer v. Franchise Tax Board (1977) 19 Cal.3d 467, the court was dealing with the identical language which appears in the corresponding section of the Personal Income Tax Law, section 17204. Furthermore, the Personal Income Tax Law and the Bank and Corporations Tax Law both contain definitions of gross income which in pertinent parts are identical. (Cf. 17071 and 24271, subd. (a)(1)-(7).) " Since these statutes are obviously in pari materia, the interpretation of a sentence in one controls the interpretation of virtually the same sentence in the other." (In re Phyle 1947) 30 Cal.2d 838, 845 186 P.2d 134.) The California resident taxpayer in Beamer had paid a Texas "'occupation tax' on the business of producing natural gas and crude petroleum" measured by the "'market value' of the oil and gas 'as and when produced' . . . ." (19 Cal.3d at p. 470.) In the case of oil sold for cash, the value was deemed to be the producer's gross cash receipts. The California taxpayer was deemed a producer under Texas law of his share of the oil produced and when it was sold his share of the value was the same as his gross royalty receipts. The court held that the Texas tax was deductible. The court reasoned as follows. The basic premise was the court's statement: We read our statutory language, 'taxes on or according to or measured by income,' to use the term 'income' in the sense of gross income under general tax law as currently operating." (19 Cal.3d at p. 479.) Then, because the taxpayer was required to be treated as in the business of mining, the court referred to existing state and federal tax regulations to define gross income of such businesses, saying in this respect ( id., at p. 476): "Relevant regulations of both the Franchise Tax Board (Cal. Admin. Code, tit. 18, reg. 17071(c)) and the Internal Revenue Service (Treas. Reg. 1.61-3(a)(1960)) provide in part that 'In a manufacturing, merchandising, or mining business, "gross income" means the total sales, less the cost of goods sold . . . .'" These regulations were characterized as a recognition of the fact that gross receipts of such businesses include "'receipts which may constitute capital as well as income'" and "'returns of capital may not be taxed.'" (Id., at p. 477.) As applied to a mining business, the court found these regulations meant that "lifting costs" were required to be subtracted from the gross receipts in order to determine the gross income. The court's interpretation of "income' as meaning "gross income under general tax laws currently operating" was, therefore, an indispensable element of its decision and not a dictum as MCA contends. This is made more apparent by the concurring opinion of Justice Sims in Beamer who states the view obviously not shared by the majority that the restriction on deductibility "is strictly limited to taxes on or according to or measured by net income or profits." ( Id., at p. 480.)