Mr Cooper Group Inc fka COOP

[bkshadow]

Fried Frank's Email - Tax Attributes...

...and that was what they were hiding.

They knew the abandonment would trigger a huge NOL, unrestricted by IRC 382 (even before the debtor confirmed such with a Private Letter Ruling). That is why they (the SNH's) wanted WMMRC; for the tax attributes; for the NOLs; in the billions; for themselves; going private; for holders of PIERS; in lieu of cash.

In 12/2009 AAOC challenged JPM due to the fact Rosie was giving everything of the estate to JPM. They accused each other of wrong doing and then signed settlement term sheets in 3/2010, dividing the former 350 billion dollar estate with each other and there was no tax attributes ever mentioned at this time.

Yeah, there was. It wasn't public yet, until December 2, 2010 during arguments. They had to divulge the "email." Fully noted in the hearing transcripts as one of the BULLET POINTS FOR THE SETTLEMENT.

Great finding for retailers and the Equity Committee.