These carry forwards are an asset to the Estate. It may not be $$ value today, but to emerging entity, it has value. This is how preferreds come in.
As the Examiner states, $500 mill out of the money, however, with our DD (thanks Dudebug), she showed us where the Examiner allocated $400 mill too much on the bond/noteholder's side which makes us (preferreds) only off by $100 mill.
Taking the above into account, IF THE BUCKS stops here, then the preferreds would get the remaining reorganized entity, i.e. preferreds converted to new common.
Carry forwards may not get money from the IRS, however, if the new WMI utilizes the carry forwards on their profit, WMI retains any money that would have been paid in taxes and NOT pay any taxes up to the carry forward amount.
We are entitled to the benefits of the future utilization of the carry forwards = no tax paid on earning results in recovery for the first line in equity.
As I mentioned before, preferreds are (will be) the fulcrum group under this POR.
A competing POR will be different of course.
BTW: I do agree with you about the numbers everyone else is "spewing". I am not in that crowd. I try to take the worst case scenario in mind.