Holding Co. has no operations other than its ownership of two wholly-owned subsidiaries, Retailer and Wholesaler. Retailer is incorporated in California. Retailer sells products in California stores and also ships products to Colorado customers via a warehouse located in Washington. Retailer claims protection from income tax in Colorado under P.L. 86-272.
Wholesaler is incorporated and has its principal place of business in Delaware. Wholesaler sells products from its Delaware warehouse to customers in California and Colorado. On a separate company basis, Wholesaler limits its activities in California and Colorado to those described in P.L. 86-272.
In 2019, Retailer had California sales of $500,000 and Colorado sales of $2,000,000. Wholesaler had California sales of $500,000 and Colorado sales of $2,000,000.
If California applied the Joyce rule what would Holding Co. & Subsidiaries' California sales numerator be?