In spirit, yes, but I think this is a matter of debate and ultimately will need to be decided by the tax courts. The states are following the letter of the law

In spirit, yes, but I think this is a matter of debate and ultimately will need to be decided by the tax courts. The states are following the letter of the law but definitely circumventing the spirit of the law. This really comes down to how much leeway the Federal government, more specifically the tax courts, gives the IRS.