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PROCTER & GAMBLE CO. v. C.I.R.

Nos. 91-1515, 91-1557.

961 F.2d 1255 (1992)

The PROCTER & GAMBLE COMPANY, Petitioner-Appellee, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant.

United States Court of Appeals, Sixth Circuit.

Decided April 20, 1992.

Attorney(s) appearing for the Case

Padric K. O'Brien, William Sanford Corey (Briefed), Sutherland, Asbill & Brennan, Washington, D.C., Burgess L. Doan (Briefed), Cohen, Todd, Kite & Stanford, Newport, Ky., J.D. Fleming, Jr. (Argued), Sutherland, Asbill & Brennan, Atlanta, Ga., for petitioner-appellee.

Abraham N.M. Shashy, Jr., Chief Counsel, John T. Lyons, I.R.S., Office of Chief Counsel, Gary R. Allen, Acting Chief (Briefed), Jonathan S. Cohen, Teresa McLaughlin (Argued), U.S. Dept. of Justice, Appellate Section Tax Div., Howard A. Berger, I.R.S., Washington, D.C., for respondent-appellant.

Before: KENNEDY and BATCHELDER, Circuit Judges; and TAYLOR, District Judge.

KENNEDY, Circuit Judge.

The Commissioner of Internal Revenue appeals the decision of the Tax Court holding that allocation of income to Procter & Gamble (P & G) from a wholly-owned subsidiary under Internal Revenue Code § 482 was unwarranted. For the reasons to follow, we AFFIRM the Tax Court.

I.

P & G is an Ohio corporation engaged in the business of manufacturing and marketing consumer and industrial products. P & G operates...

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