Does it Work, Inc. (Work) is a national provider of quality control services for the pharmaceutical industry, and has many customers in Minnesota. Work sales personnel routinely visit potential and existing customers in Minnesota. Sales personnel are authorized to solicit orders and transmit such orders outside the State for acceptance or rejection. If accepted, all of Work's services are provided from outside Minnesota.

In addition, Work sales personnel are responsible for collecting both current and delinquent accounts. Work has no other activities in Minnesota.

Are Work's activities protected under P.L. 86-272 from the imposition of a net income tax by Minnesota?

A. Yes. Works activities are limited to the solicitation of orders and activities that are ancillary to such solicitation.

B. No. P.L. 86-272 applies only to sales of tangible personal property. Sales of services are not protected.

C. Yes. The Court in Wrigley held that activities typically assigned to sales personnel are protected, provided that Work does not have an office, plant or warehouse in Minnesota.

D. No. Although most of Work's activities are protected, collecting current and delinquent accounts is not a protected activity under P.L. 86-272.