The judgment of this court, 961 F.2d 813, has been reversed. Therefore, this case is ordered remanded to the district court for further proceedings consistent with the decision of the Supreme Court of the United States in Department of Revenue of Oregon v. ACF Industries, Inc., et al., ___ U.S. ___, 114 S.Ct. 843, 127 L.Ed.2d 165 (1994).