Durbin Corporation is incorporated and has its commercial domicile in State N. This year, Durbin sold its manufactured products to customers in State N (61 percent of sales), State O (28 percent of sales), and State P (11 percent of sales). Durbin has nexus with State N and State O. However, it has no physical presence in State P and therefore is not taxed by that state. Both State N and State O use the three-factor UDITPA formula to apportion income.
Identify the tax issue or issues suggested by the above situations, and state each issue in the form of a question.