Your client, Ecru Limited, uses a small sales force to solicit sales of its whole sale restaurant supplies. Ecru is based in State W, and the sales representatives are assigned territories in States X, Y, and Z. Ecru owns no property and employs no other personnel outside of W.

As Ecru's tax adviser, you are to write a policy manual listing various "do's and don'ts" for the sales personnel so that Ecru does not create income tax nexus with X, Y, and Z.

To prepare for your assignment, write a memo for the tax research file, summarizing the rules as to the ability of a corporation to terminate or create income tax nexus. Make certain that you discuss the Wrigley case in your analysis.