Norwest Corporation and Subsidiaries, Successor in Interest to United Banks of Colorado, Inc., and Subsidiaries, et al. - Page 91

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          of the affiliated group, which had an NOL of $341,183 and a bad             
          debt deduction of $136,881, the bad debt portion of the NOL was             
          determined to be $136,881.                                                  
               After determining the bad debt portion of each loss bank               
          member's NOL, UBC allocated the consolidated 1987 NOL among the             
          group's loss members and, in the case of the loss bank members,             
          between the bad debt and the nonbad debt portions of their NOLs.            
          The allocation was made in proportion to the aggregate of the loss          
          members' NOLs.  For example, $41,861 of the consolidated 1987 NOL           
          was allocated to the bad debt portion of Aurora-South's NOL (The            
          bad debt portion of Aurora South’s NOL was $136,881; the                    
          consolidated NOL, as adjusted by respondent, was $9,239,383, and            
          the aggregate of all loss members’ NOLs, as adjusted by respondent          
          was $38,752,008.  So, $32,636 = $136,881 x (9,239,383 �                     
          38,752,008).)  The sum of $48,710 of the consolidated 1987 NOL, as          
          adjusted by respondent, was allocated to the nonbad debt portion of         
          Aurora-South’s NOL. (The nonbad debt portion of Aurora South’s NOL          
          was $204,302; $48,710 = $204,302 x (9,239,383 � 38,752,008).)               
               After allocating the consolidated 1987 NOL among the loss              
          members, UBC determined the bad debt portion of the consolidated            
          1987 NOL by aggregating the portions of the consolidated 1987 NOL           
          allocated to the bad debt portions of the loss bank members' NOLs.          
          The bad debt portion so determined was $8,731,874, of which                 
          $2,152,283 was attributable to separate return limitation year              
          (SRLY) bank members and $6,579,591 was attributable to non-SRLY             
          bank members.  Based thereon UBC claimed consolidated 1987 NOL              




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