184
Opinion of the Court
III
A
It has long been settled that a sale of tangible goods has a sufficient nexus to the State in which the sale is consummated to be treated as a local transaction taxable by that State. McGoldrick v. Berwind-White Coal Mining Co., 309 U. S. 33 (1940) (upholding tax on sale of coal shipped into taxing State by seller). So, too, in addressing the interstate provision of services, we recently held that a State in which an interstate telephone call originates or terminates has the requisite Commerce Clause nexus to tax a customer's purchase of that call as long as the call is billed or charged to a service address, or paid by an addressee, within the taxing State. Goldberg, supra, at 263. Oklahoma's tax falls comfortably within these rules. Oklahoma is where the ticket is purchased, and the service originates there. These facts are enough for concluding that "[t]here is 'nexus' aplenty here." See D. H. Holmes, supra, at 33. Indeed, the taxpayer does not deny Oklahoma's substantial nexus to the in-state portion of the bus service, but rather argues that nexus to the State is insufficient as to the portion of travel outside its borders. This point, however, goes to the second prong of Complete Auto, to which we turn.
B
The difficult question in this case is whether the tax is properly apportioned within the meaning of the second prong of Complete Auto's test, "the central purpose [of which] is to ensure that each State taxes only its fair share of an interstate transaction." Goldberg, supra, at 260-261. This principle of fair share is the lineal descendant of Western Live Stock's prohibition of multiple taxation, which is threatened whenever one State's act of overreaching combines with the possibility that another State will claim its fair share of the value taxed: the portion of value by which
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