By Don Griswold and Marty Dakessian ( December 7, 2020, 4:12 PM EST) -- We predict the 2020s will see just as seismic a shift in state tax constitutional law as the 2010s did with South Dakota v. Wayfair Inc.[1] Single-sales-factor apportionment will be subjected to a modern, nuanced judicial analysis, and another decades-old foundational precedent, Moorman Manufacturing Co. v. Bair[2] — upholding single-sales factor against constitutional challenge — will be reversed....
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