Allied-Signal, Inc. v. Director, Division of Taxation, 504 U.S. 768 (1992)

A. "Did the Court's opinion in Allied-Signal broaden the unitary business principle as articulated in prior cases. If so, how? Does the unitary business principle differ depending on which of the following two questions is being asked: (1) Is income from one portion of the taxpayer's business includable in the taxpayer's apportionable tax base (2) Is income from a particular transaction includable in the taxpayer's apportionable tax base (the question in Allied-Signal)? Suppose the question is whether income from two separate corporate entities is includable in a single apportionable tax base. Does this affect the unitary business analysis?..."