Sealy Corporation and Subsidiaries, f.k.a. The Ohio Mattress Company and Subsidiaries, et al. - Page 10

                                             10                                              
                2. Specified Liability Losses                                                
                Section 172(f) defines a specified liability loss in                         
          pertinent part as follows:                                                         
                     (1) In general.--The term “specified liability                          
                loss” means the sum of the following amounts to the                          
                extent taken into account in computing the net                               
                operating loss for the taxable year:                                         
                         *      *     *     *     *     *     *                              
                           (B) Any amount (not described in subparagraph                     
                     (A)) allowable as a deduction under this chapter                        
                     with respect to a liability which arises under a                        
                     Federal or State law * * * if--                                         
                                (i) * * * the act (or failure to act)                        
                           giving rise to such liability occurs at least                     
                           3 years before the beginning of the taxable                       
                           year,                                                             
                          *     *     *     *     *     *     *                              
                     A liability shall not be taken into account under                       
                     subparagraph (B) unless the taxpayer used an                            
                     accrual method of accounting throughout the period                      
                     or periods during which the acts or failures to                         
                     act giving rise to such liability occurred.                             
                     (2) Limitation.--The amount of the specified                            
                liability loss for any taxable year shall not exceed                         
                the amount of the net operating loss for such taxable                        
                year.                                                                        
                The 10-year carryback for specified liability losses                         
          described in section 172(f)(1)(B) applies if:                                      
                (1) The taxpayer took the specified liability loss into                      
          account in computing its net operating loss for the taxable year;                  
                (2) the expense resulting in the specified liability loss is                 
          deductible under chapter 1 of the Internal Revenue Code;                           






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Last modified: May 25, 2011