Federal Tax Research 10th Edition by Steven Gill, Gerald Whittenburg, Roby Sawyers, Debra Sanders, William Raabe

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EmiLu Corporation is a private delivery company that hires independent contractors with their own trucks to deliver car parts to various auto repair shops in Pennsylvania. EmiLu contracts with the manufacturers of the car parts to make the deliveries, and then it hires the drivers in Pennsylvania to deliver the parts. EmiLu has no property, employees, or customers in Pennsylvania. EmiLu is incorporated in Delaware, where all the car-part-manufacturing customers are located. Is EmiLu subject to the corporate franchise tax in Pennsylvania