T.C. Memo. 1997-47 UNITED STATES TAX COURT UTILICORP UNITED, INC. & SUBSIDIARIES, F.K.A. MISSOURI PUBLIC SERVICE CO., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8563-94. Filed January 27, 1997. S, a subsidiary of P, purchased certain of the assets of a reconstructed hydroelectric power facility and immediately leased those assets back to the seller. R determined that S should have allocated a portion of the asset purchase price to goodwill or going concern value. P contends that a reallocation is inappropriate because S acquired no going concern value or goodwill. Held: P has proven that the fair market value of the listed assets acquired by S, which did not include going concern value or goodwill, equaled or exceeded the price paid for them; therefore, S need not allocate any portion of that purchase price to goodwill or going concern value.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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