McColgan

J.—Plaintiff, a Minnesota corporation, with its principal place of business in St. Paul, Minnesota, is engaged in the business of selling law books and other publications *707 throughout the United States and in foreign countries. It has not qualified to do intrastate business in California, During 1937, 1938 and 1939 it shipped books and other publications into this state pursuant to orders taken here by its employees. During this time it had four regularly employed solicitors in this state who devoted their entire time to plaintiff’s business. Its California employees were authorized to receive payments on orders taken by them, to collect delinquent accounts, and to make adjustments in case of complaints by customers. The employees were given space in the offices of attorneys in return for the use of plaintiff’s books stored in such offices. In legal newspapers and periodicals published and circulated in California, plaintiff advertised as its local offices those occupied by its employees. It refused to file returns under the California Corporation Income Tax Act (Stats. 1937, ch. 765, p. 2184, as amended by Stats. 193.9, ch. 1049, p. 2902; Deering’s Gen. Laws, Act 8494a) * for…