Applying the lower of cost or market and arm's-length price principles Even assuming the taxpayer has properly written down
its inventory in compliance with the regulations and Thor Power, the Sec.
If a noncurrent marketable security's cost basis was written down
because an other-than-temporary decline occurred, "the new cost basis shall not be changed for subsequent recoveries in market value.
74 million) will be fully written down
in approximately 16 months, at which time losses will begin to impact the M2V bond.
6 million) will be entirely written down
in about 38 months, at which time the class M will begin taking losses.
The final cost forecasts for both projects will be written down
in total by SEK125m.
All classes, except for class B, which was written down
to $0 in July 2005 as a result of losses, have the benefit of a letter of credit (LOC) provided by First Union National Bank to absorb future losses.
However, class B-2 was paid off in October 2002, the senior LOC was drawn down to $0 in May 2003, and class B-1 was written down
to $0 in August 2004.
The downgrades of the B-I-1 and the B-I-2 bonds reflect the likelihood of class B-I-3 being fully written down
in as little as six months at which time the class B-I-2 will begin taking principal write downs.
In the series 1997-1 transaction, overcollateralization (OC) has been fully depleted, and the high level of losses incurred has resulted in the adjusted certificate principal balance of class B-2 being written down
Non-rated classes B3, B4 and B5 have already been fully written down
due to losses.