Hess v. Department of Revenue of Illinois, 386 U.S. 753, 87 S.Ct. 1389, 18 L.Ed.2d 505 (1967) and Quill Corporation v. North Dakota, 504 U.S. 298, 112 S.Ct. 1904, 119 L.Ed.2d 91 (1992). MBNA claims these two cases “underpin[] all commerce clause nexus analysis.” (See Pet’r Br. at 12-16.) Consequently, the resolution of this case hinges on: 1) whether the holdings of Bellas Hess and Quill control, and, if not, 2) whether economic presence satisfies the substantial nexus requirement for purposes of Indiana’s FIT. Before 1967, the Supreme Court explained that when determining whether a nexus existed between a taxing State and a taxpayer, physical presence was not the sole factor. See, e.g., Nw. States Portland Cement v. Minnesota, 358 U.S. 450, 452, 79 S.Ct. 357, 3 L.Ed.2d 421 (1959) (<HOLDING>). Then, in 1967, the Supreme Court held that
holding that a state may tax the net income from the interstate operations of a foreign corporation  provided the levy is not discriminatory and is properly apportioned to local activities within the taxing state forming sufficient nexus to support the same holding that the actual amount of capital employed in the state by a foreign corporation was to be based on the property of the corporation that was within the state and that was used in business transacted within the state holding that resident shareholder of s corporation is eligible for tax credit for taxes paid by corporation in another state and noting that this conclusion is consistent with the internal revenue code which provides that shareholders of an s corporation are entitled to a foreign tax credit for their share of foreign income tax paid by an s corporation holding that interest received by a foreign corporation on a tax refund from the united states was interest on an interestbearing obligation of a resident of the united states within income tax statute holding that net farm income when applied to a producer in the fishing industry means net income from all fishing activity not just that income from a particular commodity and further providing that the regulations make it reasonably clear that the determination of   net fishing income is not to be made solely on the basis of tax return information if other information is relevant to determining the producers net income from all   fishing sources