carguy, it is simple...
...the WMB loans were sold to JPMorgan Chase, as reported by WMI the Debtor, the FDIC the Receiver and JPMorgan Chase, the buyer, which reported such on it's 2008 Audited Financial Statements and Annual 10K (and every year since). They cannot be secretly withheld from reporting by the FDIC-R, because they are ON THE BOOKS at JPMorgan Chase. There is no double counting, at least by the actual parties to the transaction.
The NOL came about from the abandonment of WMB by WMI the debtor, that generated a $6B NOL prorated from an $8-$9B NOL based on the date of abandonment as it related to 365 days in the tax year. WMI has such a LOW BASIS in WMB because WMB had huge tax losses in 2008, magnified by the seizure by OTS, receivership by FDIC-R and bargain gift sale to JPMorgan Chase for $1.9B to the FDIC-R, and NOTHING TO WMI, the parent holding company.
The 2008 losses were used to garner almost $6B of NOL carryback tax refunds that were used, via the GSA, to get the creditor parties to settle. WMB, and WMI, would not have had losses if WMB still OWNED THESE LOANS as some purport. The IRS would have disallowed such. These loans will NOT REAPPEAR as some purport, as WMB and WMI would have to give the $6B in NOL tax refunds they got BACK TO THE TREASURY. That can't happen, the money has already been paid to the creditors, and used in settlement in the GSA.
Again, there no 'having it both ways.
It cannot be asserted that WMB loans were never sold, and no losses took place, without admitting that the $6B in tax refunds from the "losses on selling WMB assets and loans for huge losses" has to GO BACK.
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