the application of its internal and external consistency tests. See Jefferson Lines, 514 U.S. at 185, 115 S.Ct. at 1338 (“For over a decade now, we have assessed any threat of malapportionment by asking whether the tax is ‘internally consistent’ and, if so, whether it is ‘externally consistent’ as well” (citations omitted)); Goldberg, 488 U.S. at 261, 109 S.Ct. at 589 (“we determine whether a tax is fairly apportioned by examining whether it is internally and externally consistent”). As recognized by the Commonwealth Court, an apportionment method is considered internally consistent if, in a hypothetical application by all taxing jurisdictions, no more than one hundred percent of the unitary business’s income or value is taxed. See Container Corp., 463 U.S. at 169, 103 S.Ct. at 2942 (<HOLDING>). Presently, however, Unisys has not attempted
recognizing that the internal consistency standard is satisfied where the formula if applied by every jurisdiction  would result in no more than all of the unitary  businesss income being taxed holding that the pslra imposes a more rigorous pleading standard than applied by any of the courts of appeals prior to the enactment of the statute holding that if a state case explicitly states that the state standard is more favorable to the defendant than the federal standard the federal claim is considered adjudicated below when the state standard is applied holding that the standard of review for an award of statutory damages is even more deferential than an abuse of discretion standard holding that the standard for withholding of removal is more demanding than the standard for asylum