Utilicorp United, Inc. & Subsidiaries, F.K.A. Missouri Public Service Co. - Page 1

                                 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.                                                         

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