In 2019, Frump Retail, Inc. makes $300,000 of tire sales (in 2000 separate transactions) to customers living in State Brown. Frump Retail, Inc. does not own or lease property in State Brown and employs no individuals in State Brown.

Under its laws, State Brown requires foreign companies (corporations organized somewhere other than State Brown) to collect sales tax if they make more than $100,000 of sales of taxable property into the State in at least 50 separate transactions. Frump Retail Inc. does not collect the tax.

True or False: State Gray can, more likely than not MLTN, impose a law levying a gross receipts tax on Frump Wholesale, Inc.