Lehman Brothers Financial SA (LEHNQ)

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LAMCO CAN UTILIZE THE NOLs USING ASSSETS AND subject to IRC 382

a. Asset Dispositions
The Plan does not specify the manner in which assets will be disposed of
in order to satisfy Claims. However, that notwithstanding, certain assets may be
disposed of over time during the pendency of the Plan that may produce taxable income.
LBHI’s NOL carryforward should generally be available to offset any tax gains or
operating income that might be realized over time as LAMCO manages the Debtor’s
business operations and disposes of certain Debtor’s assets, subject to the potential
application of section 382 of the IRC, as discussed below. See Section A.3.b.ii—
“Internal Revenue Code Section 382 Limitations—Possible Application to the LBHI Tax
Group.”