Wisconsin Department of Revenue v. William Wrigley, JR., Co. (505 U.S. 214)
U.S. Supreme Court · decided June 19, 1992 · Supreme Court Database (Spaeth)
- Citation
- 505 U.S. 214 · 112 S. Ct. 2447
- Decided
- June 19, 1992
- Term
- October Term 1991
- Vote
- 6–3
- Majority author
- Justice Scalia
- Issue area
- Economic Activity
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
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 parts of other States, which was subdivided into several geographic territories. The district manager for the midwestern district had his residence and company office in Illinois, and visited Wisconsin only six to nine days each year, usually for a sales meeting or to call on a particularly important account. The regional manager of the Milwaukee region resided in Wisconsin, but Wrigley did not provide him with a company office. He had general responsibility for sales activities in the region, and would typically spend 80-to-95%…
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