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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