Looking at receipts arising from the sale of services. Often the provider of the services is in one state; while the recipient of the services is in another state. Sourcing these receipts, for apportionment of income purposes, raises the question - which state should these receipts be apportioned to? The trend is recent years is to source such receipts to -

a.The place - the state - of incorporation of the provider.

b.The location state of the recipient of these services.

c.The location state where the predominant cost of performing such services was.

d.Wherever a state tax auditor decides he or she can assign as the source state, and get away with regardless of the law.