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Wednesday, January 17, 2018 4:45:18 PM
The NOLs of the LBHI Tax Group (including
Debtor-Controlled Entities) are subject to audit and
adjustment by the IRS and primarily expire in or
about 2028. Substantially all of the LBHI Tax
Group’s current consolidated net operating loss
carryovers are attributable to the Debtors. The Plan
provides for an orderly liquidation of the Debtors.
As previously disclosed in the Company’s Quarterly
Financial Report as of March 31, 2012 [Docket No.
29731], the LBHI Tax Group received a private letter
ruling from the IRS in connection with the Plan going
effective that stated (i) the liquidation of the Debtors
for U.S. federal income tax purposes may occur over
an extended period, and (ii) the reduction of the
LBHI Tax Group’s NOLs as a result of the discharge
of debt pursuant to the Plan generally would not
occur until completion of the liquidation. Upon
completion of the liquidation of the Debtors, all
remaining NOLs of the Debtors will be eliminated.
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