QUAD GRAPHICS v. N.C. DEP'T OF REVENUE

No. 407A21.

881 S.E.2d 810 (2022)

2022-NCSC-133

QUAD GRAPHICS, INC. v. N.C. DEPARTMENT OF REVENUE.

Supreme Court of North Carolina.

Filed December 16, 2022.


Attorney(s) appearing for the Case

Akerman, LLP, by Michael J. Bowen , pro hac vice; and Douglas W. Hanna , Raleigh, for petitioner-appellee.

Joshua H. Stein , Attorney General, by Ryan Y. Park , Solicitor General, and Ashley Hodges Morgan , Special Deputy Attorney General, for respondent-appellant.

Poyner Spruill LLP, Raleigh, by Caroline P. Mackie ; and Caroline S. Van Zile , Principal Deputy Solicitor General for the District of Columbia, for Steve Marshall , Attorney General for the State of Alabama, Treg R. Taylor , Attorney General for the State of Alaska, Philip J. Weiser , Attorney General for the State of Colorado, Karl A. Racine , Attorney General for the District of Columbia, William Tong , Attorney General for the State of Connecticut, Lawrence G. Wasden , Attorney General for the State of Idaho, Kwame Raoul , Attorney General for the State of Illinois, Theodore E. Rokita , Attorney General for the State of Indiana, Thomas J. Miller , Attorney General for the State of Iowa, Brian E. Frosh , Attorney General for the State of Maryland, Maura Healey , Attorney General for the Commonwealth of Massachusetts, Keith Ellison , Attorney General for the State of Minnesota, Aaron D. Ford , Attorney General for the State of Nevada, Andrew J. Bruck , Acting Attorney General for the State of New Jersey, Hector Balderas , Attorney General for the State of New Mexico, Letitia James , Attorney General for the State of New York, Wayne Stenehjem , Attorney General for the State of North Dakota, Josh Shapiro , Attorney General for the Commonwealth of Pennsylvania, Peter F. Neronha , Attorney General for the State of Rhode Island, Thomas J. Donovan Jr. , Attorney General for the State of Vermont, and Robert W. Ferguson , Attorney General for the State of Washington, amici curiae.

Q Byrd Law, by Quintin D. Byrd ; Fayetteville, and Richard Cram , pro hac vice, for Multistate Tax Commission, amicus curiae.

William W. Nelson , Raleigh, for North Carolina Chamber Legal Institute, amicus curiae.


¶ 1 Respondent appeals from the Business Court's decision, in which the tribunal had concluded that the sales of printed materials produced by Wisconsin-based petitioner out of state and shipped to its customers and their designees located within North Carolina lacked a sufficient nexus to North Carolina for the imposition...

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