Initial Letter Date |
Form filed |
Market Capitalization |
06/08/2012 |
10-Q |
$ 2,390 M |
We note that you recorded a significant tax benefit during the quarter ended March 31, 2012 which reduced your effective tax rate to 5.2% for the quarter. We further note your disclosure that this tax benefit was related to certain losses on the 2009 Debt Exchange that were previously considered non-deductible. Please provide us with more information on the nature of these expenses and what caused you to change your conclusion as to their tax deductibility during the first quarter of 2012. As part of your response, please clarify whether the additional research performed included consultation with the IRS about the deductibility of these items. |