In Matter of British Land (Md.) v. Tax Appeals Trib.of State of N.Y. (85 N.Y.2d 139, 647 N.E.2d 1280, 623 N.Y.S.2d 772 [1995]), the Court summarized the multistate business case law as follows: "A formula-based tax on income may be struck down if the income attributed to the State is in fact out of all appropriate proportions to the business transacted by the taxpayer in that State or if application of the apportionment formula has led to a grossly distorted result. The taxpayer bears the burden of showing by clear and cogent evidence that application of the formula results in extraterritorial values being taxed" (id. at 146).