The Wrigley case held that the sale of intangibles is protected by Public Law 86-272.

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The Wrigley case (Wrigley Jr. Co. v. Wisconsin Department of Revenue, 1992) primarily dealt with the issue of whether certain activities conducted by a company's sales representatives within a state constituted a level of business activity sufficient to allow the state to impose a net income tax, in light of Public Law 86-272. The case did not hold that the sale of intangibles is protected by Public Law 86-272; rather, it focused on the activities related to the solicitation of orders for tangible personal property.

The Wrigley Case Held That the Sale of Intangibles Is