You represent ABC Corporation, a New Jersey S-corporation that has 3 shareholders, Abbey, Bobby and Charlie. Abbey and Bobby are domiciliaries of New York. Charlie is a domiciliary of New Jersey. Charlie owns an apartment in New York which he purchased as an investment. Charlie spends approximately 200 days in New York per year. ABC Corporation sells sporting goods and sporting good equipment throughout the United States. All purchase orders are processed in New Jersey and shipped from a distribution warehouse located in the State where delivery of goods will occur using independent truck drivers. Each warehouse is owned and managed by an unrelated entity. The corporation does not have any stores, offices or employees in any other State other than New Jersey. However, ABC Corporation does keep its books and records in NYS with its accounting firm. In addition, ABC corporation occasionally sends independent salesman into a particular State, including New York, to market and sell their goods to box-store distributors such as Modells, Footlocker and Footaction. The independent salesman not only attempt to make sales but will occasionally pass product inquires and complaints of the stores to ABC, as well as, assist in displaying the sporting good products in the store.

Question:

Allocation of S Corp income at Shareholder level. We know partnership can allocate if it has another office in another state. Find authority on when S Corp can allocate out of state.