Stryker Corporation, a Michigan Corporation, Plaintiff-Appellant v. Director, Division of Taxation…

Summary

The Supreme Court of New Jersey affirmed the Appellate Division, holding that Stryker's receipts from drop‑shipment sales to its New Jersey subsidiary are "other business receipts" earned within New Jersey and must be included in the receipts fraction under N.J.S.A. 54:10A-6(B)(6); the Court also held that this inclusion does not violate the Commerce Clause's internal‑consistency test. Justice STEIN filed a concurring opinion addressing the amici's undue‑burden argument.