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Zardiw

12/05/08 11:10 AM

#45322 RE: liu #45316

There is a question of whether the NOL's will transfer. WMI is in a unique situation because it no longer has a bank, although on paper it is a bank holding company. BUT if the IRS allows the NOL's to transfer, then JPM would have an incentive to buy it.

But if they merge with another company/bank, and we end up owning 50% or more of the resulting entity, then the NOL's WILL transfer.

http://209.85.173.132/search?q=cache:sVcT3Il5i_oJ:www.mondaq.com/article.asp%3Farticleid%3D67740+%22net+operating+loss%22+bank+holding+company+acquisition+irs&hl=en&ct=clnk&cd=1&gl=us

SO, there is incentive to restructure, rather than liquidate....z