Which of the following is not a consideration in determining whether a state tax is a tax based on net income:

A, Application of P.L. 86-272

B, Whether the state tax is deductible for federal and / or state income tax purposes.

C, Whether the state tax is one that may be subjected to Commerce Clause scrutiny

D, Whether the state tax paid to another state is creditable in the taxpayer's state of domicile.

E, None of the above