On Date 1, Oldco formed Newco, a State A corporation. (ii) On Date 2, Newco formed LLC, a State A limited liability company that will be treated as a disregarded entity for federal income tax purposes. On Date 3, Oldco merged with and into LLC, with LLC as the surviving entity. In the merger, the Oldco shareholders exchanged their shares of Oldco stock for shares of Newco stock. Steps (i) through (iii), collectively, are referred to as the “Potential Reorganization.” [...]
Neither did Oldco FORM Newco, nor did Newco (if WMIH or COOP) create a new LLC, nor did Oldco(!) merge with and into LLC...
Then one could stop reading IMO. But also the following points don't match...
So I think you are right...
Your post:
Yet another IRS PLR that supposedly proves Escrow $$ are coming....I can already smell new theories being "cooked" up.