Saturday, January 21, 2023 9:29:29 AM
>>6. As set forth in the Motion, the Debtors estimate that, as of the date thereof,
Lehman had accrued NOLs of $48 billion. According to the Debtors, any Tax Attributes that
remain at the time of emergence from bankruptcy could prove to be of significant value to the
reorganized Debtors by reducing future U.S. federal income tax liabilities. However, the ability
of the Debtors to use the Tax Attributes to offset future taxable income is subject to certain
limitations, which are contained in Sections 382 and 383 of the Internal Revenue Code of 1986
(as amended from time to time, and together with the Treasury Regulations promulgated
thereunder, the “Tax Code”). <<
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