Section 6.02 Consistent Treatment . for Fairpoint

Send us Feedback

Fairpoint Communications (FRP)

	SUMMARY

	BULLS

	BEARS

	TOPICS

	DATA CENTRAL

	STOCK CHART

	SEC FILINGS

	BALANCE

	INCOME

	CASH FLOW

FRP » Topics » Section 6.02 Consistent Treatment .

This excerpt taken from the FRP 8-K filed Jan 19, 2007.

Section 6.02 Consistent Treatment.

(a) Unless and until there has been a Final Determination to the contrary, each party agrees to treat (i) each of (A) the Contribution, together with the Distribution and (B) the first Internal Spinoff, as a tax–free reorganization qualifying under Section 368(a)(1)(D) of the Code, (ii) each of the Internal Spinoffs and the Distribution as a transaction qualifying under Sections 355 and 361 of the Code, (iii) the Debt Exchange (if consummated) as a transfer of qualified property to Verizon’s creditors in connection with the reorganization within the meaning of Section 361(c)(3) of the Code; and (iv) the Merger as a reorganization qualifying for nonrecognition under Section 368(a) of the Code, pursuant to each of which no gain or loss is recognized by any of Verizon, Spinco, FairPoint and their respective shareholders and Subsidiaries (except to the extent of cash received in lieu of fractional shares).

(b) Unless and until there has been a Final Determination to the contrary, FairPoint shall file or cause to be filed all Tax Returns of a member of the Spinco Group or relating to the Spinco Business and shall conduct any Tax Contests in respect of a

member of the Spinco Group or the Spinco Business in a manner consistent with Verizon’s determination of the adjusted Tax basis of any asset and the amount of any Tax Attribute or any similar item held by the Spinco Group at the time of the Distribition.

Wikinvest © 2006, 2007, 2008, 2009, 2010, 2011, 2012. Use of this site is subject to express Terms of Service, Privacy Policy, and Disclaimer. By continuing past this page, you agree to abide by these terms. Any information provided by Wikinvest, including but not limited to company data, competitors, business analysis, market share, sales revenues and other operating metrics, earnings call analysis, conference call transcripts, industry information, or price targets should not be construed as research, trading tips or recommendations, or investment advice and is provided with no warrants as to its accuracy. Stock market data, including US and International equity symbols, stock quotes, share prices, earnings ratios, and other fundamental data is provided by data partners. Stock market quotes delayed at least 15 minutes for NASDAQ, 20 mins for NYSE and AMEX. Market data by Xignite. See data providers for more details. Company names, products, services and branding cited herein may be trademarks or registered trademarks of their respective owners. The use of trademarks or service marks of another is not a representation that the other is affiliated with, sponsors, is sponsored by, endorses, or is endorsed by Wikinvest.

Mobile | Advertise | Licensing & Partnerships | Blogger Tools | Jobs

Fairpoint Communications (FRP)

FRP » Topics » Section 6.02 Consistent Treatment .

Section 6.02 Consistent Treatment.

(b) Unless and until there has been a Final Determination to the contrary, FairPoint shall file or cause to be filed all Tax Returns of a member of the Spinco Group or relating to the Spinco Business and shall conduct any Tax Contests in respect of a

member of the Spinco Group or the Spinco Business in a manner consistent with Verizon’s determination of the adjusted Tax basis of any asset and the amount of any Tax Attribute or any similar item held by the Spinco Group at the time of the Distribition.