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Opinion of the Court
Justice Scalia delivered the opinion of the Court.
Section 101(a) of Public Law 86-272, 73 Stat. 555, 15 U. S. C. § 381, prohibits a State from taxing the income of a corporation whose only business activities within the State consist of "solicitation of orders" for tangible goods, provided that the orders are sent outside the State for approval and the goods are delivered from out of state. The issue in this case is whether respondent's activities in Wisconsin fell outside the protection of this provision.
I
Respondent William Wrigley, Jr., Co., is the world's largest manufacturer of chewing gum. Based in Chicago, it sells gum nationwide through a marketing system that divides the country into districts, regions, and territories. During the relevant period (1973-1978), the midwestern district included a Milwaukee region, covering most of Wisconsin and
General, and by the Attorneys General for their respective States as follows: Grant Woods of Arizona, Daniel E. Lungren of California, Richard Blumenthal of Connecticut, Robert A. Butterworth of Florida, Michael J. Bowers of Georgia, Warren Price III of Hawaii, Larry EchoHawk of Idaho, Linley E. Pearson of Indiana, Robert T. Stephan of Kansas, Frederic J. Cowan of Kentucky, William J. Guste, Jr., of Louisiana, J. Joseph Curran, Jr., of Maryland, Scott Harshbarger of Massachusetts, Hubert H. Humphrey III of Minnesota, William L. Webster of Missouri, Marc Racicot of Montana, Don Stenberg of Nebraska, Tom Udall of New Mexico, Robert Abrams of New York, and Lacy H. Thornburg of North Carolina; for the State of New Jersey et al. by Robert J. Del Tufo, Attorney General of New Jersey, and Mary R. Hamill and Sarah T. Darrow, Deputy Attorneys General, Charles E. Cole, Attorney General of Alaska, and Winston Bryant, Attorney General of Arkansas; for the City of New York by O. Peter Sherwood, Edward F. X. Hart, and Stanley Buchsbaum; and for the Multistate Tax Commission by Paull Mines.
Briefs of amici curiae urging affirmance were filed for the Committee on State Taxation of the Council of State Chambers of Commerce by Amy Eisenstadt and Paul H. Frankel; and for the Direct Selling Association by Mario Brossi, Joseph N. Mariano, M. Douglas Adkins, Neil J. O'Brien, and Camille R. Comeau.
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