Procter & Gamble Company v. United States

Analysis Group was retained by the Tax Division of the U.S. Department of Justice to provide economic and accounting analysis in this intangible-assets valuation and transfer-pricing dispute. The DOJ had assessed federal income taxes and interest against Procter & Gamble for the taxable years ended June 30, 2000, through June 30, 2005, for deductions P&G had claimed for donations of its patents to universities and charities. A team including Managing Principals Jeffrey Cohen and Richard Starfield supported our academic affiliates Sebastian Edwards and Toby Stuart and performed a series of accounting, statistical, and econometric analyses to determine the value of the patents claimed as deductions or transferred across P&G entities.