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Re: FORTY-8 post# 321201

Saturday, 07/16/2011 2:13:16 PM

Saturday, July 16, 2011 2:13:16 PM

Post# of 731898
William: "...valuing the re-org company at $350M + $1.68B (or 20% of $24B, which is $4.8B, which would be, under the ideal circumstances of In Re Coram, further adjusted down to $1.68B (or 35% of $4.8B) = a net total present valuation of $2.03B."


I believe you are reducing the NOLs down too much in the steps you are using. We all know that the only way the NOLs have value is to have a merger/acquisition that allows for the use.

So, for example, using your figure of $24B in NOLS, I would take the 35% (the max taxable rate for corporations) reduction first and you get $8.4B in possible tax refunds.

Anyone merging with NewCo to take advantage of the NOLs would definitely want to acquire them at a reduced rate to see at least a 50% return on their investment.

So even if they paid at a 50% discount, WMMRC (NewCo) could see value for the NOLs at about $4.2B. That is a little less than 20% of the original amount of NOLs.


Just my thoughts on how to calculate the NOLs value.



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