Answer this in 3 or four sentences. Here is the last part of the question. The position of the document was that the tax due of $314674.

Answer this in 3 or four sentences. Here is the last part of the question. The position of the document was that the tax due of $314674.62 on the catalogs that were used by Penny's Massachusetts customers. Pennys said such a tax was unconstitutional in that it had no control or contract with the catologs in the state. Can it impose that tax? Why or why not? (Commissioner of Revenue v. JC Penny Co inc)