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Essay text:
Appellant conducts its unitary business through various subsidiaries, including Disc, in California, other states, and foreign countries.
During the appeal years Disc, also a California corporation, manufactured and sold a line of sophisticated scientific instruments somewhat different from those of appellant to customers inside and outside of California. Disc maintained its own sales staff and had its own customers. Disc was not taxable in any of those states outside of California into which it made sales although appellant, itself, was taxable in those states.
In computing the sales factor appellant treated Disc's out-of-state sales as non-California sales and applied the destination rule...
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