We were engaged by outside counsel to assist them as accounting experts in the representation of their client in a series of disputes/cases with the IRS that were litigated in the United States Tax Court.  The disputes related to the IRS’s assertion that intercompany debt incurred by the US entities should have been characterized as equity rather than debt.  The total intercompany debt in question was several billion dollars.  We performed numerous analyses, including using bank statements to track actual cash movement across numerous entities.  We also prepared quarterly cash flow statements for all of the entities in question and reconciled cash flow to reported operating income.