Procter & Gamble Co. v. United States

OPINION AND ORDER

MICHAEL H. WATSON, District Judge.

Plaintiffs in this action, Procter & Gamble Company (“P & G”) and Proctor & Gamble FSC (“P & G FSC”)(collectively, “plaintiffs”), seek a refund of taxes paid pursuant to assessments by the government. One of the assessments concerned the FSC Advance Payment Transaction. At the administrative level, the government defended the assessment on the ground that plaintiffs’ calculation of Combined Taxable Income (“CTI”) resulted in a material distortion of income. In the present lawsuit, the parties filed cross-motions for summary judgment on the…