"the Plan Administrator shall wind-down, sell and otherwise liquidate assets of the Debtors and/or Debtor- Controlled Entities" - plenty of debtor entities out there that they don't control but have equity in (2500+?)
"it being understood that such liquidation may include the transfer of all or part of the assets of such Debtor to one or more Liquidating Trusts" - all or part of the assets
"should not result in a reduction or limitation of the Debtors’ tax attributes for federal income tax purposes that materially impairs the expected actual use of such tax attributes" - the Plan Administrator obviously wants to use the NOLs for a going concern, otherwise they would just liquidate without the need for a letter from the IRS...
Thanks for posting that section of the POR Jimzin!