Vodafone’s Tennessee customers to vanish, for tax purposes. This qualifies as an “unusual fact situation” that produces an “incongruous result.” See BAPCO, 308 S.W.3d at 367 (“The unusual fact situation in this case is that all of the costs of production occurred outside of Tennessee, but the revenue derived from the end product only occurred when the product was distributed in Tennessee .... ”); accord Microsoft Corp. v. Franchise Tax Bd., 39 Cal.4th 750, 47 Cal.Rptr.3d 216,139 P.3d 1169, 1181 (2006) (disagreeing with taxpayer’s contention that the frequency with which issue of large corporate treasury department receipts arises renders situation as “nonu-nique” under California variance regulation); Union Pac. Corp. v. Idaho State Tax Comm’n, 139 Idaho 572,83 P.3d 116, 120 (2004) (<HOLDING>). We also- agree with the Commissioner that
recognizing that it is an unusual challenge to a sale that does not distort the validity of the sale and that the exception likely has meaning only when collateral issues are challenged holding in the analogous context of choiceoflaw in relation to the sale of personal property that compensation for arranging the sale is assessed apart from underlying sale holding that the amendment was a use regulation which was in effect a condition on the use of property in the affected zone holding that effect of different accounting systems was unusual under the idaho variance regulation even if underlying situation the sale of receivables was not unique recognizing that sale of insurance affects the public interest and is subject to state regulation