Norwest Corporation and Subsidiaries, Successor in Interest to United Banks of Colorado, Inc., and Subsidiaries, et al. - Page 93

                                        - 93 -                                        
          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, $32,636 of the                     
          consolidated 1987 NOL (as adjusted by respondent) 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.              
          Thus, $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, respondent, in the notice, like UBC on the Form 1139,              
          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 $6,263,417, of which $1,677,978 was               
          attributable to SRLY bank members and $4,585,439 was attributable           
          to non-SRLY bank members.  Based thereon the notice allowed NOL             
          carrybacks to the UBC affiliated group's taxable year 1977 of               
          $4,585,439 (non-SRLY bank members) and taxable year 1981 of                 
          $268,839 (SRLY carryback).                                                  





Page:  Previous  79  80  81  82  83  84  85  86  87  88  89  90  91  92  93  94  95  96  97  98  Next

Last modified: May 25, 2011