The U.S. District Court here in Cincinnati has decided a dispute over the application of the deliberative privilege in a case involving $1 billion in charitable deductions claimed by Proctor & Gamble. Proctor & Gamble Co. v. United States, No. 1:08-cv-608 (S.D. OH, Dec. 31, 2009).  Among the claimed charitable deductions were P&G's donations of intellectual property technologies and 80 paintings to the Cincinnati Art Museum and the National Underground Railroad Freedom Center. P&G requested that the government produce documents underlying IRS's appraisals of the donated artwork and technologies during discovery. The government asserted the deliberative process privilege and withheld many of the requested documents. P&G moved to compel the production of the documents on the ground that the privilege was not applicable to factual and investigative documents.