Haig Corporation, a manufacturer, is a multistate taxpayer that has nexus with States 1 and 2. During the taxable
year, Haig’s net sales were $2,000,000; $1,200,000 of these sales were made in State 1, and $800,000 were made in State 2. The corporation also received $300,000 from the rental of nonbusiness real property located in State 1. Both states employ a three-factor apportionment formula under which sales, property, and payroll are equally weighted. However, the states do not agree on the definition of apportionable income. Under State 1’s tax provisions, nonbusiness rent income is allocable and business income is apportionable, while State 2 requires a corporation to apportion all of its (business and nonbusiness) income.