- 4 - policyholders after the controversies were resolved and the cases were closed. Cases were often open for more than 1 year. Some bills from P&G to CSAA were for litigation costs only, some were for legal fees (services) only, and some were for both costs and fees. P&G’s fees were paid by CSAA at a stated hourly rate. P&G claimed as a deduction litigation costs it paid on behalf of CSAA’s policyholders, either from the $400 retainer or as advances, in the year that it paid the litigation costs. P&G reported the $400 retainers and the reimbursements of litigation costs as income in the year they were received by P&G. P&G’s deductions for litigation costs were as follows: Fiscal year ending Litigation costs May 31, 1990 $262,771.60 May 31, 1991 280,332.39 May 31, 1992 382,365.84 May 31, 1993 358,092.07 May 31, 1994 254,562.73 P&G reported retainers and reimbursed litigation costs as income as follows: Retainers and reimbursed Fiscal year ending litigation costs May 31, 1991 $242,867.08 May 31, 1992 361,880.37 May 31, 1993 377,767.17 May 31, 1994 276,686.05 Respondent, in the notice of deficiency, disallowed a portion of the total deduction petitioner claimed for litigation costs, reduced income by the amount of reimbursed previouslyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011