Amerada Hess Corp. v. Director, Div. of Taxation, N. J. Dept. of Treasury

In Amerada Hess Corp. v. Director, Div. of Taxation, N. J. Dept. of Treasury, 490 U. S. 66, 80 (1989), the Supreme Court rejected outright the idea that geographically assignable costs of production must be excluded from an apportionment of income: "Just as each taxpayer's oil-producing revenue-as part of a unitary business - is not confined to a single State, Exxon Corp., 447 U. S., at 226, . . . so too the costs of producing this revenue are unitary in nature. See Container Corp., 463 U. S., at 182 (the costs of a unitary business cannot be deemed confined to the locality in which they are incurred)." (Ibid.)