In Appeal of Joyce, Inc. (Nov. 23, 1966), the State Board of Equalization (SBE) determined that Public Law No. 86-272 (Sept. 14, 1959) 73 Statutes at Large 555 (15 U.S.C. 381 et seq.) prevented the state from considering income from a member of a unitary group where the individual member's sole contact in California was sales representatives who solicited, but could not accept, orders in the state. Public Law No. 86-272 protects an out-of-state corporation from state income taxes if its only activity in the state is: "the solicitation of orders . . . for sales of tangible personal property, which orders are sent outside the state for approval or rejection, and, if approved, are filled by shipment or delivery from a point outside the state . . . ." (15 U.S.C. 381(a)(1).) Joyce involved an Ohio corporation and its California subsidiary, both of which sold shoes in California. Only the subsidiary was subject to taxation in California. The SBE concluded that inbound sales by the parent company, which was not subject to tax in California, could not be included in the allocation formula for purposes of calculating the sales factor, even though another member of the group was taxable in California. Joyce was the rule in California from 1966 until 1988. Under Joyce, if the individual seller had not been subject to tax in the foreign state, its foreign sales would have been thrown back to the state of origin. The SBE reached its new result by interpreting the word "taxpayer" in this portion of the Revenue and Taxation Code to mean all members of a unitary group. In addition, in Joyce the SBE had been concerned that the federal statute (15 U.S.C. 381(a)) would be interpreted in an expansive manner to restrict taxation of unitary groups.