Proctor & Gamble vs. United States of America Ruling

On June 25, 2010, the U.S. District Court ruled on The Proctor & Gamble Company (P&G) vs. United States of America in favor of P&G. P&G and the IRS have had a long-standing accepted method on Gross Receipts computation as it relates to the Section 41 credit determination. Historically, the accepted method was to treat […]

United States Vs. McFerrin No. 08-20377 …

A Step in the Right Direction In a step forward, the fifth circuit has correctly interpreted the Section 41 R&E Credit Rules and applied them retroactively to void prior decisions and misinterpretations of the tax code. Case Background: McFerrin, co-founder of KMCO, Inc. a manufacturer of commodity and specialty chemicals, mainly to the petrochemical industry, […]