Wrigley Jr. Company in selling and supplying retailers with chewing gum exceeded limits defined by Congress in 1961 that exempted foreign corporations from franchise and income taxes in a state as long as their activities were limited to soliciting customers.

Wrigley, based in Chicago, neither owned nor leased any real property in the state.

[2] Wisconsin believed that the presence of Wrigley in the state was enough to call for a franchise tax.

The state believed that Wrigley was not afforded protection under Public Law 86-272, because it violated solicitation by the following practices: The state argued for the narrowest possible view: that any activity beyond “asking the customer to purchase the product” removed the protection of P.L.86-272.

The Court found that Wrigley’s activities in Wisconsin exceeded the provisions of the state code and allowed the imposition of the tax.