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Economic Analysis: So Far, 133 Companies Report Over $5 Billion in CARES Act NOL Refunds

Posted on June 29, 2020

Based on a review of SEC filings as of June 24, Tax Notes estimates that 133 companies will receive between $5.3 billion and $8.9 billion in tax refunds from recently enacted relaxations of limits on the use of net operating losses. The individual businesses and their reported expected refunds — or our estimates of their expected refunds — are listed in the table below. This is likely only a small sample of things to come.

A large portion of the NOL-related refunds reported so far are for losses incurred in 2018 and 2019. Because of the pandemic, the extent and magnitude of tax losses will be much larger in 2020 than in earlier years. An important caveat to the suggestion that a much larger total of refunds is in the offing is that the reduction in taxable income that would result from carryback of NOLs may affect other provisions in the law in such a way that makes the total income tax effect of carrybacks on net unfavorable.

In their SEC filings to date, some firms report they expect no significant benefit from the NOL provisions of the Coronavirus Aid, Relief, and Economic Security (CARES) Act (P.L. 116-136). In general, taxpayers will look more favorably on carrybacks to pre-Tax Cuts and Jobs Act years than carrybacks to 2018 and 2019 because the TCJA’s reduction in the corporate tax rate and imposition of provisions that depend on taxable income make 2018 and 2019 carrybacks less valuable.

Many businesses report that they are still evaluating potential benefits. The ongoing evaluation is entirely expected because the potential negative interactions with other law provisions are complex. Further, the magnitude of tax losses for 2020 is still unknown, both because of the underlying economic uncertainty and because an array of tax planning opportunities may be available to increase losses.

The CARES Act (Mostly) Temporary Relief

The TCJA, signed into law on December 22, 2017, eliminated the carryback of losses incurred after 2017; under pre-TCJA law, they could have been carried back two years. The TCJA limited the ability of NOLs to reduce taxable income to 20 percent of its pre-NOL level; previously, NOLs could zero out taxable income. A third TCJA change was taxpayer-favorable: Newly generated NOLs could be carried forward indefinitely instead of expiring after 20 years under prior law. (This last change “cost” Congress nothing because there was no revenue impact inside the 10-year budget window, while at the same time it could provide some companies with a significant accounting benefit because it allowed them to keep or restore loss carryforwards as an asset on their balance sheets.)

The CARES Act temporarily and retroactively reversed the TCJA’s de-escalation of NOL benefits. Losses incurred in 2018, 2019, and 2020 can be carried back five years with no limitation on their ability to reduce taxable income in years as far back as 2013, but not after 2020. Businesses can generate refunds by filing amended returns for 2018 and, if already filed, for 2019. Alternatively, they can file Form 1139 to receive a tentative refund more quickly.

The ability to generate losses both currently in 2020 and retroactively in 2018 and 2019 was enhanced by other provisions of the CARES Act. The TCJA imposed a limitation on interest deductions equal to 30 percent of adjusted taxable income. The CARES Act increases the 30 percent adjusted taxable income threshold to 50 percent in 2019 and 2020, and it allows taxpayers to use their 2019 adjusted taxable income as their adjusted taxable income in 2020. The CARES Act also retroactively provides a technical correction to the TCJA classification of qualified improvement property as 39-year property. Now, as Congress intended, improvements to interiors of nonresidential buildings undertaken since passage of the TCJA may be either expensed or written off over 15 years.

In general, a Form 1139 application for tentative refund must be filed within 12 months after the end of the tax year in which the NOL arose. In Notice 2020-26, 2020-18 IRB 1, the IRS granted a six-month extension of time to file Form 1139. Thus, for NOLs that arose in 2018, taxpayers must file no later than June 30, 2020.

Tax Benefits and Cash Refunds

In their SEC filings, some companies plainly state they are expecting to receive a refund — or in accounting terminology, they have recorded a tax receivable — exclusively or primarily attributable to the carrybacks made available under the CARES Act, and they provide the dollar amount of that refund. (In two cases the amount of NOL carryback to pre-TCJA years is provided, and we multiplied these amounts by 0.35 to arrive at the amount of expected refunds.) These directly stated amounts of refund are shown for 70 companies in Part A of the table.

For the remaining 63 companies in Part B of the table, there was no stated amount of refund (or NOL carryback), but the amount of tax benefit exclusively or primarily provided by availability of NOL carrybacks is reported. Translating a tax benefit amount into an amount of refund can differ significantly across businesses, depending on their accounting treatment of deferred tax assets attributable to NOLs.

Allow us to explain. In accounting, the term “tax benefit” has a precise meaning. It is an accrual concept, the opposite of tax expense. Tax benefits reduce the income tax provision. The income tax provision is the numerator of the effective tax rate reported on financial statements (which may or may not provide clues to the actual tax paid by the business to tax authorities). A business generates a tax benefit when there is an unanticipated reduction in tax expense. A business can also generate a noncash tax benefit by increasing a deferred tax asset or reducing a deferred tax liability.

When a company generates tax losses that cannot be carried back, it creates a deferred tax asset. In lay terms, it has prepaid taxes so those tax prepayments are like coupons that can be used for future tax payments due to the IRS. Importantly, those coupons for prepayment of tax are only an asset if there is a good expectation that there will be future taxable income to which the NOLs can be applied before they expire. If, based on some complicated and sometimes subjective accounting guidelines, NOLs are not expected to be used, a business must reduce its deferred tax assets by what is called a valuation allowance. (In accounting lingo, the valuation allowance is a contra asset to the deferred tax asset.)

If a business has poor prospects for future profitability, it may have to increase its valuation allowance (which will reduce the value of its net deferred tax assets). This would be a noncash expense that increases the income tax provision and the effective tax rate. Sometimes a business will have a valuation allowance that totally offsets the value of its tax loss carryforwards.

With this background, let’s consider the impact of a $100 operating loss incurred in 2018 carried back to 2013 when taxable profit was $100. Assume for simplicity that there is zero taxable profit in all other years through 2020, and assume no other tax provisions are affected by the carryback. The business can expect a $35 refund. How much this will reduce accounting income tax expense (or, equivalently, how much it will increase income tax benefit) depends on the accounting for carryforwards.

In the plain vanilla case, a business with no valuation allowance would have had a deferred tax asset of $21 because it expected the $100 of NOL generated in 2018 would eventually be used to offset $100 of profit taxed at 21 percent. After the CARES Act unexpectedly arrived on the scene and made possible a carryback of a $100 loss to a year with a 35 percent rate, two things happen from an accounting perspective. First, the $21 of NOL deferred tax asset is transformed into a $21 tax receivable (and when the refund is received, the $21 tax receivable on the balance sheet is replaced with $21 of cash). This has no impact on the tax provision. All that has happened is that a long-term asset has been converted into a short-term asset.

The $14 of benefit attributable to the rate differential, however, is a different story. It also has become a tax receivable, but it is not offset by any other item on the balance sheet. It is unexpected. It is manna from heaven. It is a windfall. And it is recorded as a reduction in tax expense (or, equivalently, an increase in income tax benefit) of $14. This does reduce the tax provision and the effective tax rate. The bottom line, in this case, is that if we observe a reported $14 tax benefit attributable to an NOL carryback, we know the amount of expected refund is $35. To put it more generally, we know the refund is 2.5 (=35/14) times the reported income tax benefit.

We can observe this as reality in several cases shown in the table, where both the expected refund and the income tax provision are reported. Take, for example, Aaron’s Inc., which reported it will carry back $242.2 million of NOLs to pre-TCJA years to get an expected refund of $84.4 million (35 percent of $242.2 million is $84.4 million). Aaron’s also reports an income tax benefit of $34.2 million. That tax benefit times 2.5 equals the expected $84.4 million refund.

What if the same business had a $100 valuation allowance that totally offset the $100 deferred tax asset attributable to the NOL carryforward? In effect, from an accounting perspective, the business is totally surprised by the CARES Act. There is no net reduction in deferred tax assets because their value was zero from the start. The increase in tax receivables of $35 is not offset. In this case, the amount of refund is equal to the reported tax benefit.

So, to review, we have two polar cases. In the first, the refund is 2.5 times the reported tax benefit. In the second, the refund is equal to the reported tax benefit. Lots of intermediate cases are possible. For example, a business may have partial valuation allowance, or carrybacks may be partially to years after 2017 when the corporate rate was 21 percent. That is why in the table for the 63 businesses in Part B, we say the total amount of carrybacks is between 100 percent ($2,382 million) and 250 percent ($5,279 million) of reported tax benefits ($2,382 million). And this is why we conclude that for the 133 companies in the table, the estimated expected refunds resulting from the carryback provisions of the CARES Act are overall between $5.3 billion and $8.9 billion.

Limitations

Our estimates of total refunds are based on a computer search of SEC filings from March 23 through June 24. The search terms included items such as “CARES Act,” “net operating loss,” ”tax refund,” ”tax benefit,” ”tax receivable,” and “carryback.” Once those terms were located, human eyeballs had to read the surrounding text and ascertain if there was sufficient information to identify an amount of refund attributable to NOL carrybacks. It is likely in the reading of the texts from numerous filings that some businesses reporting cash refunds or tax benefits from CARES Act NOLs were overlooked.

Also, in some cases significant amounts of NOL carrybacks seemed probable, but dollar amounts could not be separately identified from other tax provisions. For example, the Gap Inc. reports in its most recent 10-Q: “The increase in the effective tax rate [from 24.8 percent to 26 percent, computed on a pre-tax loss of $1.3 billion] is primarily due to the net operating loss carryback provisions of the CARES Act and changes in the mix of pretax income between domestic and international operations.” Any estimate of NOL-related refunds based on that type of information was deemed too speculative and excluded from our estimate.

Companies with less than $100 million in annual revenue were excluded from the search. And businesses identified with refunds of less than $1 million were excluded from our total. Finally, it should be kept in mind that a search of SEC financial data includes only publicly traded companies. Some large privately held companies could be anticipating significant refunds but aren’t included in our estimate.

Looking Back and Forward

To help counter the devastation of the Great Recession, Congress enacted the Worker, Homeownership, and Business Assistance Act of 2009 (P.L. 111-92) on November 6, 2008. This law temporarily extended the NOL carryback period from two years to five years for NOLs generated in either 2008 or 2009 (whichever was chosen by the taxpayer). The homebuilding industry was among the hardest hit, and homebuilders collectively received billions of dollars of refunds from NOL relief.

For example, William Lyon Homes reported an anticipated tax refund of $101.8 million for the carryback of a 2009 tax loss to 2004 and 2005. KB Home was able to carry back its 2009 NOLs to offset earnings it generated in 2004 and 2005, and it applied for a federal tax refund of $190.7 million. Because of the legislation, Lennar Corp. received a tax refund of about $320 million in early 2010. And PulteGroup Inc. in 2010 received $934.7 million of refunds resulting primarily from the carryback of taxable losses made possible by the 2009 law. It has been only a little over three months since passage of the CARES Act. It remains to be seen over the following year if large refunds like those received in 2010 materialize.

133 Companies Reporting Benefits From CARES Act NOL Provisions
(as of June 24, 2020; dollar amounts in millions)

Company

SEC Form

SIC Code

Line of Business

Anticipated Cash Refund (if reported)

Accounting Tax Benefit (if reported)

Part A. Companies reporting amount of refund

Limoneira Co.

10-Q (Q2 ‘20)

100

Agriculture

$4.9

$1.4

Occidental Petroleum Corp. /DE/

10-Q (Q1 ‘20)

1311

Oil & Gas

$195

 

W&T Offshore Inc.

8-K

1311

Oil & Gas

$1.9

 

Noble Corp. PLC

10-Q (Q1 ‘20)

1381

Oil & Gas

$151.4

$42.6

Frank’s International NV

10-Q (Q1 ‘20)

1389

Oil & Gas

$17.5

 

Superior Energy Services Inc.

10-Q (Q1 ‘20)

1389

Oil & Gas

$30

 

Liberty Oilfield Services Inc.

10-Q (Q1 ‘20)

1389

Oil & Gas

$9.3

 

U.S. Well Services Inc.

10-Q (Q1 ‘20)

1389

Oil & Gas

$0.8

 

Limbach Holdings Inc.

10-Q (Q1 ‘20)

1700

Construction

$1.6

 

Oxford Industries Inc.

10-Q (Q1 ‘20)

2320

Clothing

$8

 

Flexsteel Industries Inc.

10-Q (Q3 ‘20)

2510

Furniture

$9

 

A.H. Belo Corp.

10-Q (Q1 ‘20)

2711

Publishing

$2.3

 

McClatchy Co.

10-K (FY ‘19)

2711

Publishing

$9

 

Advansix Inc.

10-Q (Q1 ‘20)

2821

Chemicals

$8

 

Akorn Inc.

10-Q (Q1 ‘20)

2834

Pharmaceuticals

$24.6

 

Mallinckrodt PLC

10-Q (Q1 ‘20)

2834

Pharmaceuticals

$91.5

$11.5

Forma Therapeutics Holdings Inc.

424B4

2836

Biologic Products

$30.3

 

Flotek Industries Inc. /CN/

10-Q (Q1 ‘20)

2890

Chemicals

$6.1

$2.1

Trecora Resources

10-Q (Q1 ‘20)

2911

Oil & Gas

$14

$5.7

James Hardie Industries PLC

6-K

3272

Manufacturing

$87.6

$25.9

Forum Energy Technologies Inc.

10-Q (Q1 ‘20)

3533

Oil & Gas

$14.3

$16.6

National Oilwell Varco Inc.

10-Q (Q1 ‘20)

3533

Oil & Gas

$123

 

Trinity Industries Inc.

10-Q (Q1 ‘20)

3743

Transport

$303

$154.7

Canadian National Railway Co.

6-K

4011

Transport

$351

$141

Seacor Holdings Inc. /New/

8-K

4412

Transport

$32

 

Allegiant Travel Co.

10-Q (Q1 ‘20)

4512

Transport

$194

 

Providence Service Corp.

10-Q (Q1 ‘20)

4700

Transport

$27.8

$11.1

E.W. Scripps Co.

10-Q (Q1 ‘20)

4833

Broadcast

$13.9

 

Intelsat SA

10-Q (Q1 ‘20)

4899

Communications

$8.1

 

Antero Midstream Corp.

10-Q (Q3 ‘19)

4922

Oil & Gas

$55

$11

Targa Resources Corp.

10-Q (Q1 ‘20)

4922

Oil & Gas

$44.2

 

Consolidated Edison Inc.

10-Q (Q1 ‘20)

4931

Services

$2.5

$4

Stericycle Inc.

10-Q (Q1 ‘20)

4955

Waste Management

$100

$39.4

Owens & Minor Inc. /VA/

10-Q (Q1 ‘20)

5047

Medical

$13

$5.2

A.M. Castle & Co.

10-Q (Q1 ‘20)

5051

Wholesale

 

 

A-Mark Precious Metals Inc.

10-Q (Q3 ‘20)

5094

Jewelry

$3.4

 

Global Partners LP

10-Q (Q1 ‘20)

5171

Oil & Gas

$15.3

$6.3

Adams Resources & Energy Inc.

10-Q (Q1 ‘20)

5172

Oil & Gas

$6.4

 

Lumber Liquidators Holdings Inc.

10-Q (Q1 ‘20)

5211

Retail

$4.9

 

Dillard’s

10-Q (Q1 ‘20)

5311

Retail

$40

$14.8

Express Inc.

10-Q (Q1 ‘20)

5600

Retail

$57.9

$19.5

Francesca’s Holdings Corp.

8-K

5600

Retail

$10.7

 

Cheesecake Factory Inc.

10-Q (Q1 ’20)

5812

Retail

$36

 

Fiesta Restaurant Group Inc.

10-Q (Q1 ‘20)

5812

Retail

$2.3

 

Chuy’s Holdings Inc.

10-Q (Q1 ‘20)

5812

Retail

$3

 

Big 5 Sporting Goods Corp.

10-Q (Q1 ‘20)

5940

Retail

$2.1

 

Kearny Financial Corp.

10-Q (Q3 ‘20)

6035

Finance

$4.2

$1.6

Nicholas Financial Inc.

10-K (FY ‘20)

6153

Finance

$4.5

$1.8

CPI Card Group Inc.

10-Q (Q1 ‘20)

6153

Finance

$5.6

 

Ocwen Financial Corp.

10-Q (Q1 ‘20)

6162

Finance

$62.9

 

Proassurance Corp.

8-K

6331

Finance

$12

 

Kingstone Cos. Inc.

10-Q (Q1 ‘20)

6331

Finance

$2.4

 

Colony Capital Inc.

10-Q (Q1 ‘20)

6798

Real Estate

$8.6

 

Healthpeak Properties Inc.

10-Q (Q1 ‘20)

6798

Real Estate

$8

 

Taubman Centers Inc.

10-Q (Q1 ‘20)

6798

Real Estate

$3.2

 

Penn National Gaming Inc.

10-Q (Q1 ‘20)

7011

Hotels

$45

 

Harte Hanks Inc.

10-Q (Q1 ‘20)

7331

Services

$11.2

 

Aaron’s Inc.

8-K

7359

Services

$84.4

$34.2

Synchronoss Technologies Inc.

10-Q (Q1 ‘20)

7371

Services

$9

 

3D Systems Corp.

10-Q (Q1 ‘20)

7372

Services

$8.9

$3.2

Commvault Systems Inc.

10-K (FY ‘20)

7372

Services

$10

 

Liveramp Holdings Inc.

10-K (FY ‘20)

7374

Services

$32

 

Performant Financial Corp.

10-Q (Q1 ‘20)

7380

Services

$3.9

 

Envestnet Inc.

10-Q (Q1 ‘20)

7389

Services

$16.1

 

AMC Entertainment Holdings Inc.

10-Q (Q1 ‘20)

7830

Retail

$18.5

 

Cinemark Holdings Inc.

10-Q (Q1 ‘20)

7830

Retail

$20

 

Marcus Corp.

10-Q (Q1 ‘20)

7830

Retail

$20

 

Diversicare Healthcare Services Inc.

10-Q (Q1 ‘20)

8051

Services

$321

 

Universal Technical Institute Inc.

10-Q (Q2 ‘20)

8200

Services

$11.2

 

Premier Inc.

10-Q (Q3 ‘20)

8741

Services

$7.3

$2.9

Part B. Companies reporting tax benefit (but not amount of refund)

Magnolia Oil & Gas Corp.

10-Q (Q1 ‘20)

1311

Oil & Gas

 

$1.2

Diamondback Energy Inc.

10-Q (Q1 ‘20)

1311

Oil & Gas

 

$25

Curo Group Holdings Corp.

8-K

1311

Oil & Gas

 

$9.1

NCS Multistage Holdings Inc.

10-Q (Q1 ‘20)

1389

Oil & Gas

 

$1.4

B&G Foods Inc.

10-Q (Q1 ‘20)

2000

Food

 

$2.3

Hain Celestial Group Inc.

10-Q (Q3 ‘20)

2000

Food

 

$12.6

Bridgford Foods Corp.

10-Q (Q2 ‘20)

2013

Food

 

$1.1

Guess? Inc.

10-Q (Q1 ‘21)

2340

Clothing

 

$11.8

GCP Applied Technologies Inc.

10-Q (Q1 ‘20)

2800

Chemicals

 

$2.8

Akcea Therapeutics Inc.

10-Q (Q1 ‘20)

2834

Pharmaceuticals

 

$1.7

Amneal Pharmaceuticals Inc.

10-Q (Q1 ‘20)

2834

Pharmaceuticals

 

$110

Retrophin Inc.

10-Q (Q1 ‘20)

2834

Pharmaceuticals

 

$19

Endo International PLC

10-Q (Q1 ‘20)

2834

Pharmaceuticals

 

$137

Assertio Therapeutics Inc.

10-Q (Q1 ‘20)

2834

Pharmaceuticals

 

$146

Westlake Chemical Corp.

424B5

2860

Chemicals

 

$62

Valero Energy Corp. /TX/

10-Q (Q1 ‘20)

2911

Oil & Gas

 

$110

Marathon Petroleum Corp.

10-Q (Q1 ‘20)

2911

Oil & Gas

 

$411

Core Molding Technologies Inc.

10-Q (Q1 ‘20)

3089

Manufacturing

 

$5.6

Iconix Brand Group Inc.

10-Q (Q1 ‘20)

3140

Manufacturing

 

$6.3

Eagle Materials Inc.

10-K (FY ‘20)

3241

Manufacturing

 

$31.7

McDermott International Inc.

10-Q (Q1 ‘20)

3443

Manufacturing

 

$12.7

Vista Outdoor Inc.

10-K (FY ‘20)

3480

Manufacturing

 

$7

Power Solutions International Inc.

10-Q (Q1 ‘19)

3510

Manufacturing

 

$0.8

Astec Industries Inc.

10-Q (Q1 ‘20)

3531

Manufacturing

 

$9.5

Fitbit Inc.

10-Q (Q1 ‘20)

3571

Electronics

 

$146

Casa Systems Inc.

10-Q (Q1 ‘20)

3663

Electronics

 

$9.3

First Solar Inc.

10-Q (Q1 ‘20)

3674

Electronics

 

$88.7

Spartan Motors Inc.

10-Q (Q1 ‘20)

3711

Transport

 

$2.6

Surmodics Inc.

10-Q (Q2 ‘20)

3841

Manufacturing

 

$1.8

Fossil Group Inc.

10-Q (Q1 ‘20)

3873

Electronics

 

$61

Nautilus Inc.

10-Q (Q1 ‘20)

3949

Manufacturing

 

$3.2

USD Partners LP

10-Q (Q1 ‘20)

4013

Electronics

 

$0.5

United States Cellular Corp.

10-Q (Q1 ‘20)

4812

Broadcast

 

$50

Cable One Inc.

10-Q (Q1 ‘20)

4841

Broadcast

 

$7

Centerpoint Energy Inc.

10-Q (Q1 ‘20)

4911

Services

 

$19

UGI Corp. /PA/

10-Q (Q2 ‘20)

4932

Oil & Gas

 

$19.2

Beacon Roofing Supply Inc.

10-Q (Q2 ‘20)

5030

Construction

 

$15.9

Veritiv Corp.

10-Q (Q1 ‘20)

5110

Paper

 

$2.1

Burlington Stores Inc.

10-Q (Q1 ‘20)

5311

Retail

 

$62.5

Nordstrom Inc.

8-K

5651

Retail

 

$326

At Home Group Inc.

10-Q (Q1 ’21)

5700

Retail

 

$5.2

Tile Shop Holdings Inc.

10-Q (Q1 ‘20)

5700

Retail

 

$2.4

Conns Inc.

10-Q (Q1 ‘20)

5731

Retail

 

$4.9

Potbelly Corp.

10-Q (Q1 ‘20)

5812

Retail

 

$3.7

Bloomin’ Brands Inc.

10-Q (Q1 ‘20)

5812

Retail

 

$65

First Merchants Corp.

10-Q (Q1 ‘20)

6021

Finance

 

$1.2

WSFS Financial Corp.

10-Q (Q1 ‘20)

6021

Finance

 

$1.8

Sterling Bancorp

10-Q (Q1 ‘20)

6021

Finance

 

$21.3

Marlin Business Services Corp.

8-K

6022

Finance

 

$3.2

Pacific Premier Bancorp Inc.

10-Q (Q1 ‘20)

6022

Finance

 

$6.8

Peapack Gladstone Financial Corp.

10-Q (Q1 ‘20)

6029

Finance

 

$8.1

New York Community Bancorp Inc.

10-Q (Q1 ‘20)

6036

Finance

 

$13.1

Consumer Portfolio Services Inc.

10-Q (Q1 ‘20)

6199

Finance

 

$8.8

Manning & Napier Inc.

10-Q (Q1 ‘20)

6282

Finance

 

$3.3

PJT Partners Inc.

10-Q (Q1 ‘20)

6282

Finance

 

$3.7

CNO Financial Group Inc.

10-Q (Q1 ‘20)

6321

Finance

 

$34

Franchise Group Inc.

10-Q (Q1 ‘20)

6794

Patents

 

$46.9

CarGurus Inc.

10-Q (Q1 ‘20)

7374

Services

 

$2.6

Amerco /NV/

10-K (FY ‘20)

7510

Services

 

$146

Team Inc.

10-Q (Q1’20)

7600

Services

 

$7.3

Progenity Inc.

424B4

8071

Services

 

$37.7

LHC Group Inc.

10-Q (Q1 ‘20)

8082

Services

 

$2.1

Huron Consulting Group Inc.

10-Q (Q1 ‘20)

8742

Services

 

$0.8

(1) Total refunds (from Part A)

$2,896.5

 

(2) Total tax benefits (from Part B)

 

$2,382.3

(3) Estimated lower-bound refunds from Part B [= line (2)]

$2,382.3

 

(4) Estimated upper-bound refunds from Part B [= 2.5 times line (2)]

$5,955.7

 

(5) Estimated lower-bound total NOL refunds (parts A and B) [= lines (1) + (3)]

$5,278.8

 

(6) Estimated upper-bound total NOL refunds (parts A and B) [= lines (1) + (4)]

$8,852.2

 

Source: SEC reports. In a small number of cases in Part A, the author estimates refund to be equal to tax rate times NOL carryback.

 

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