Utilicorp United, Inc. & Subsidiaries, F.K.A. Missouri Public Service Co. - Page 8

                                        - 8 -                                         
               Security for Lease Payments                                            
               The bill of sale does not provide for a sale by THP of its             
          interest in the power purchase agreement or the construction                
          contracts.  THP assigned its rights under the power purchase                
          agreement and the construction contracts to UtilCo to secure the            
          payment of rents by THP under the project lease.                            
          Purchase Price Allocation                                                   
               In making its purchase price allocation, UtilCo allocated              
          the $32,250,000 purchase price among the bill of sale assets.               
          After consummating its purchase of the undivided interest, UtilCo           
          calculated its investment tax credit, business energy tax credit,           
          and depreciation for the 1987 taxable year, using that purchase             
          price allocation.  Because UtilCo could not use all of its                  
          general business credit in the 1987 taxable year, a portion of              
          that credit was carried back to the 1984 taxable year.  UtilCo              
          did not record any goodwill or going concern value on its books             
          as a result of the acquisition of the undivided interest.                   



          Expert Testimony                                                            
               Petitioner's Expert                                                    
               Petitioner presented the expert testimony of David C. Moody,           
          vice president of Stone & Webster Management Consultants, Inc.              
          Mr. Moody is licensed in the State of Maine as a professional               
          engineer and as a real estate appraiser.  Mr. Moody is                      




Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011