in Complete Auto Transit, Inc. v. Brady, 430 U.S. 274, 97 S.Ct. 1076, 51 L.Ed.2d 326 (1977), and permit such taxation when: the tax is applied to an activity with a substantial nexus with the taxing state, is fairly apportioned, does not discriminate against interstate commerce, and is fairly related to the services provided by the state. Id. at 279, 97 S.Ct. at 1079; see also Exxon Corp. v. Wisconsin Dep’t of Revenue, 447 U.S. 207, 219-20, 100 S.Ct. 2109, 2117-18, 65 L.Ed.2d 66 (1980) (quoting Mobil Oil, 445 U.S. at 436-37, 100 S.Ct. at 1231). 11 . See also Allied-Signal, 504 U.S. at 783, 112 S.Ct. at 2260 (stating that "the constitutional test focuses on functional integration, centralization of management, and economies of scale”); Container Corp., 463 U.S. at 166, 103 S.Ct. at 2941 (<HOLDING>)! As noted, the parties here agree that Unisys
recognizing same principle recognizing the value of leveraging the governments limited enforcement resources recognizing principle but finding evidence at first trial sufficient recognizing principle recognizing breadth of unitary business principle and that it could apply not only to vertically integrated enterprises but also to a series of similar enterprises operating separately in various jurisdictions but linked by common managerial or operational resources that produced economies of scale and transfers of value