1. Exxon Mobile ("Exxon"), headquartered in Irving Texas, leases an oil tanker from a Japanese shipping company. The ship's registry is in Panama. Panama and Japan both have a tax treaty with the United States. The ship transports crude oil from the North Sea, Canada, and West Africa to Port Newark New Jersey in Union County. The crude oil is transferred to the Exxon Bayway refinery where it is refined into gasoline by Exxon. The oil refinery is located in Linden New Jersey in Union County. The refined oil is then sold to independent dealers and delivered by tanker trucks owned by Exxon Mobile Tanker Corp., a wholly-owned subsidiary of Exxon, to the neighboring states of Delaware and New York. The gasoline is sold by independent Exxon gas stations owned by independent dealers. Exxon has no offices or salespeople in New York or Delaware. Assume Exxon has no other business operations or employees in New York or Delaware. All orders are taken by phone or email in New Jersey. New Jersey and New York have a sales tax; Delaware does not have a sales tax. New Jersey has a "Throw Back Rule". All states have adopted "Wayfair legislation". The revenue from the sales of gasoline is substantial.