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James G. Kreissman, Michael H. Simonson, and Naftali Z.
Dembitzer, for petitioner.
Peter J. Graziano and Pamela L. Cohen, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
HALPERN, Judge: Petitioner Utilicorp United, Inc.
(petitioner) is the common parent corporation of an affiliated
group of corporations making a consolidated return of income (the
affiliated group). Respondent has determined deficiencies of
$2,462,443 and $229,479 in the consolidated Federal taxable
income of the affiliated group for the group’s 1984 and 1987
taxable (calendar) years, respectively. The only issue remaining
for decision is the depreciable basis of certain assets.
Respondent has determined that one member of the affiliated
group, Utilicorp, Inc. (UtilCo), improperly included in the
depreciable basis of certain property the nondepreciable cost of
goodwill or going concern value.
Unless otherwise noted, all section references are to the
Internal Revenue Code in effect for the years in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
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