I think what the Fordham Law Review is saying is that the NOLs are not considered an Asset on the Balance Sheet in a Bankruptcy. I think it is because they cannot be liquidated.
However SHC does include the value of the NOLs in the Financial Statements - 10-Q I think.
Here are the Tax Attributes that the Debtors sold to Transform Holdco - per the 8-K filed on Jan 24, 2019. There is no mention of the NOLs.
“ Certain prepaid taxes and certain rights to any refund, rebate or credit of taxes “
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