Opposition Brief — South Central Bell Telephone Co. v. Alabama

FILED

JUL 1 4 1996

No. 97-2045

OFFICE OF THE CLERK

In The SUPREME COURT. U.S.

eae

Supreme Court of the United States ~~

OCTOBER TERM, 1997

SOUTH CENTRAL BELL TELEPHONE COMPANY. et al.

Petitioners.

VS.

STATE OF ALABAMA AND

STATE DEPARTMENT OF REVENUE

Respondents.

On Petition for a Writ of Certiorari to the

Supreme Court of Alabama

BRIEF IN OPPOSITION

BILL PRYOR

Attorney General, State of Alabama

“RON BOWDEN, Counsel

Department of Revenue and Assistant

Attorney General, State of Alabama

DAN E. SCHMAELING, Assistant Counsel

Department of Revenue and Assistant

Attorney General, State of Alabama

P. O. Box 320001

Montgomery, AL 36132-0001

(334) 242-9690

“Counsel of Record for Respondents

QUESTIONS PRESENTED

1. Whether the Alabama Supreme Court's

application of state law res judicata principles to bar

the Petitioners’ federal constitutional challenge to a

state tax is, under the circumstances, so extreme as to

amount to a violation of Petitioners’ rights to due

process of law.

2. Whether Alabama's franchise tax

impermissibly discriminates against interstate

commerce by taxing Alabama corporations on the par

or stated value of their stock while taxing the

Petitioners (out-of-state corporations) on the value of

their capital employed in Alabama.

3. Whether this Court should refrain from ruling

on the appropriate remedy to apply to this case, which

involves a constitutional challenge to a state tax

statute and a request for a refund of taxes, when the

court below did not have an opportunity to rule on the

issue because it found no constitutional violation.

TABLE OF CONTENTS

PAGE

er are

Te OF ND 8 aoc ai dae Hoke tas ii

Teta Oe DO gg cov a Viren ntonveesenee itl

re mnt i a 1

1. The Proceedings Below............. 1

2. The Statutory Scheme. ............. 2

i — I Pr ee in. 4

Reasons for Denying the Writ ............--- 5

| The Alabama Supreme Court

correctly applied its valid principles

of res judicata to bar this litigation. .... 5

ll. The Alabama franchise tax on

foreign corporations does not

violate the Commerce Clause of

the United States Constitution. ....... Gq

Hl. This Court should refrain from

ruling on the remedy to be applied

(should Alabama's tax be struck

down) to allow the Alabama

Supreme Court an opportunity to

decide this issue in the first

SPP PE SL ere: 16

Cee Ss cikca oes ae tentakteas 17

TABLE OF AUTHORITIES

PAGE

Armco, inc. v. Hardesty,

Ge EE Soba a lt tie: 15

Bacchus Imports, Ltd. v. Dias,

468 U.S. 263, 270 (1984) .............. 10

Bedingfield v. Jefferson County,

Se ME Ws eee ee nel re 7

Best and Co. v. Maxwell,

ee CE ee oueics cen uete 10

Camps Newfound/Owatonna, inc. v. Town of

Harrison,

Fee es OE ove oh OUR ha tacdbieccwes )

Chemical Waste Management v. Hunt,

112 S.Ct. 2009, 2015 (1992) .......... 13

Dairyland ins. Co. v. Jackson,

566 So.2d 723 (Ala. 1990) ............. 5

Fulton Corporation v. Faulkner,

re A CE on eG vacs'deerccce at a

Green v. Wedowee Hospital,

584 So.2d 1309 (Ala. 1991) ............ 6

Harper v. Virginia Department of Taxation,

RE a COE, cade eecces 16

Henneford v. Silas Mason Co.,

is oan o-hilS'w'n we ee a 15

Martin v. Wilks,

490 U.S. 755, 109 S.Ct. 2180,

106 6.30 G5 (1008)... www. 6

TABLE OF AUTHORITIES

PAGE

v. Louisiana,

461 U.S. 7a (1GB1) ww we cee wees 15

NAACP v. Hunt,

891 F.2d 1555 C.A. 11 (Ala. 1990) ....... 6

New Energy Company of Indiana v. Limbach,

108 S.Ct. 1803 (1988), ............... 12

Oregon Waste Systems v. Department of

Environmental Quality, 511 U.S. 93, 114 S.Ct.

1345, 128 L.Ed.2d 13 (1994) ......... 9, 14

Reynolds Metals Company v. White, —

558 So.2d 373 (Ala. 1989), cert. denied |

r fil fee passim

Richards v. Jefferson County,

517 U.S. 793. 116 S.Ct. 1761 (1996) .. 5,6,7

Whisman v. Alabama Power Company,

512 So.2d 78 (Ala. 1987) .............-. 5

Code of Alabama 1975

eet fs sity kkied ws ys 2.4

OS Oe ee TT 1

§40-14-41(a), (b), (c) and (d) ........... 2,3

OO gored ee a aere 4

iv

STATEMENT OF THE CASE

1. The Proceedings Below

The Taxpayers, foreign corporations doing

business in Alabama, challenge the franchise tax

levied against foreign corporations by §40-14-41, Code

of Ala. 1975, for the years 1982 through 1991. They

stayed pending the final outcome of Reynolds Metals

Company v. White, 558 So.2d 373 (Ala. 1989), cert.

denied 496 U.S. 912 (1990). (R. 26)

The Complaints filed prior to 1991 allege that the

foreign corporation franchise tax violates the

Constitution, and the corresponding sections of the

Alabama Constitution of 1901. They later included

counts alleging violations of 42 U.S.C. §§1983 and

1988 (since abandoned), and §§44, 212 and 232,

Constitution of Alabama 1901.

The Alabama Department of Revenue denied all

claims and asserted that the Alabama foreign

provision and is valid in all respects. The Department

also countered that even if the foreign corporation

franchise tax is held to be unconstitutional, such

1

finding should be given prospective application only.

The Department also pleaded that these actions are

barred by the doctrine of res judicata, citing Reynolds,

which upheld the constitutionality of Alabama's

franchise tax regime against a similar attack.

The trial court held that the Taxpayers’ claims are

barred by res judicata. Because of the public

importance of the issues presented, however, the trial

court addressed the merits of the action, and stated its

ruling on each of the issues raised by the parties. The

court stated that it would rule in favor of the

Department on all issues except the one alleging a

violation of the Commerce Clause.

The Taxpayers appealed, the Supreme Court of

Alabama affirmed without opinion, and this petition

ensued.

2. The Statutory Scheme

The Taxpayers are classified as foreign

corporations for the purpose of paying Alabama

franchise tax pursuant to Code of Ala. 1975, §40-14-

41(a). For purposes of the Alabama franchise tax, a

foreign corporation is any corporation organized under

the laws of any state other than Alabama. §40-14-

41(a). A domestic corporation for purposes of the

Alabama franchise tax is any corporation organized

under the laws of Alabama. §40-14-40. (Stip. p.1-2)'

‘The stipulated facts were admitted into evidence as

Piaintifts’ exhibit 3. See Pet. App. 48a.

2

(Stip. p. 3)

Section 232, Constitution of Alabama 1901, provides

for and authorizes the levy of a franchise tax on

the tax base set forth in §40-14-41(d). The portion of

the total capital that is employed in Alabama is

allocated to the state pursuant to §40-14-41(c).

stock of corporations with par value capital stock, and

to the amount of the stated value of the capita! stock

of corporations with no par capital stock.

in addition to the franchise tax, domestic

corporations in Alabama pay a corporate shares tax.

which is levied on the value of the shares of their

stock. Ala. Code §40-14-70.

than they would be required to pay were they domestic

the years 1988 through 1991 are substantially

applicable to the years 1982 through 1987. (Stip.

applied by the Supreme Court Alabama in an

attempt to create a question that merits this Court's

attention. Supreme Court of Alabama not

A prior judgment on the merits; rendered by a

court of competent jurisdiction; with substantial

_ Ins. Co. v. Jackson, 566 So.2d 723 (Ala.

The party identity criterion of res judicata does

not require complete identity, but only that the party

against whom res judicata is asserted was either a

party or in privity with a party to the prior action, or

that the nonparty’s interests were adequately

represented by the parties in the prior suit, and that

the relationship between the party and the nonparty is

not so attenuated as to violate due process. Whisman

v. Alabama Power Company, 512 So.2d 78 (Ala.

1987). For res judicata purposes, privity exists where

the nonparty’s interests were represented adequately

by the party in the original suit or where a party to the

original suit is so closely aligned to a nonparty’s

interest as to be his virtual representative. NAACP v.

Hunt 891 F.2d 1555 C.A. 11 (Ala. 1990). Judgments

can bind persons not party (or privy) to the litigation in

question where the nonparty’s interests were

represented adequately by the party in the original

Suit. Green v. Wedowee Hospital, 584 So.2d

1309 (Ala. 1991).

Richards v. Jefferson County, 517 U.S. 793, 116

S.Ct. 1761 (1996), recognized an exception to the

general rule that only parties to a lawsuit are bound by

it "when it can be said that there is ‘privity’ between a

party to the second case and a party who is bound by

an earlier judgment.” As this Court explained in Martin

v. Wilks, 490 U.S. 755, 109 S.Ct. 2180, 104 L.Ed.2d

835 (1989):

We have recognized an exception to the general

rule when, in certain limited circumstances, a

person, although not a party, has its interests

adequately represented by someone with the

same interests who is a party.

Thus, it can be seen that this court has adopted

essentially the same standard as has the Supreme

Court of Alabama with regard to the party identity

criterion of res judicata. Because of the unique facts

of their situation, the standard was applied correctly to

the Taxpayers to preclude their challenge to

Alabama’s franchise tax. The Taxpayers’ unique

problem in this case is too insubstantial an issue to

justify this Court's further review.

Richards essentially held that Birmingtam’s

acting finance director and the city itself, which had

challenged the same tax in Bedingfield v. Jefferson

County, 527 So.2d 1270, did not adequately represent,

or were not in privity with, the two privately employed

taxpayers who sought to represent a class of all

nonfederal employees subject to the county’s tax. An

obvious reason for the holding in Richards is that

Birmingham's acting finance director and the city itself

are not members of the class that the privately

employed taxpayers in Richards sought to represent.

The facts of the present case are distinguishable from

Richards and support a different conclusion.

Both of the taxpayers in Aeynolds Metals

Company v. White, 558 So.2d 273 (Ala. 1989), cert.

denied 496 U.S. 912 (1990), can be said to be

members of the same class as the taxpayers in this

case. The Taxpayers’ interests were adequately

represented by the taxpayers in Reynolds.

Reynolds is a major manufacturer with extensive

plants located in the State of Alabama. Its franchis2

tax liability is substantial, so that it had every reason to

protect its interest in this area. Furthermore, Reynolds

7

and its co-plaintiffs, General Motors Corporation,

GMAC Leasing Corporation, and General Motors

Acceptance Corporation, possess the resources to

vigorously pursue their own best legal interests, and

they did so. They were represented in the prior

litigation by some of the top law firms in the State of

Alabama, which rendered to them more than

competent representation.

Both the Reynoids plaintiffs and the taxpayers In

the present cases are foreign corporations doing

business in Alabama subject to the Alabama franchise

tax. Their interests with respect to the Alabama

franchise tax parallel one another in that they both

have a substantial financial interest in seeing to it that

their franchise tax liability is minimized to the greatest

extent possible.

Furthermore, one of the taxpayers in these cases

filed a complaint during the pendency of the Reynolds

case but allowed Reynolds to go forward while its suit

remained dormant in anticipation that Reynolds would

decide the issues that they seek to have resolved.

These taxpayers filed petitions for refund with the

Department during the pendency of the Reynolds

case, and allowed those petitions to languish pending

a decision in Reynolds.

The Taxpayers are substantially identical to the

Reynolds plaintiffs in that they all constitute major

foreign corporations doing business in Alabama

*See letter to Judge Gordon from Byars dated January 19,

1990, R. 26; Pet. App. 65a.

subject to the franchise tax with identical interests with

regards to the validity of the franchise tax. In a sense

they have substantial identity or privity with the

Reynolds plaintiffs. At the very least, they constitute

nonparties to Aeynolds whose interests were

adequately represented in that case and under

Alabama law are deemed to be substantially identical

parties to the Reynolds plaintiffs.

ll. The Alabama franchise tax on foreign

corporations does not violate the Commerce

Clause of the United States Constitution

The Taxpayers argue that the Alabama franchise

tax Statute facially discriminates against interstate

commerce and thereby violates the “virtually per se

rule of invalidity” that this Court applies to

facially discriminatory taxes, and cites Camps

Newfound/Owatonna, Inc. v. Town of Harrison, 117

S.Ct. 1590 (1997); Fulton Corporation v. Faulkner, 516

U.S. 325 1996; and Oregon Waste Systems, Inc. v.

Department of Environmental Quality, 511 U.S. 93

(1994), as authority for this proposition.

The pertinent Alabama statutes do not support

the Taxpayers’ allegation. Instead, they reveal that the

measure of the franchise tax on foreign corporations is

$3.00 per $1,000.00 of capital employed by the

corporation in the State of Alabama. The measure of

the tax levied on domestic corporations is $10.00 per

$1,000.00 of capital stock of the corporation. Because

the measure of the two taxes admittedly has different

rates and bases, it cannot be determined from reading

them whether any discrimination exists. If it can be

9

said that there is any facial discrimination in these

statutes, however, it is against domestic corporations--

not foreign ones--since the domestic corporations are

taxed on all of their capital stock, whereas foreign

corporations are taxed on only the capital that they

employ within the State of Alabama; and since the rate

applied against the domestic base is $10.00 per one

thousand, while the rate applied against the foreign

base is only $3.00 per one thousand.

The Taxpayers assert that Alabama's franchise

tax "in its practical operation works discrimination

against interstate commerce.” Best and Co. v.

Maxwell, 311 U.S. 454-456 (1940), and therefore

violates the commerce clause prohibition against state

taxes that have a "discriminatory effect,” Bacchus

Imports, Lid. v. Dias, 468 U.S. 263, 270 (1984).

Reynolds held otherwise, and the evidence in this

case continues to support its holding.

The evidence shows that had the twelve named

Plaintiffs in the present case paid franchise and shares

tax to Alabama as domestic corporations rather than

as foreign corporations, their taxes in most instances

would have been increased many times over. The

increases, which are detailed in a study prepared by

the Department (attached as Appendix A to this brief),

are no less than startling in amount.* After noting that

a similar situation existed with respect to the taxes that

one of the Reynolds Plaintiffs would have paid had it

been taxed as a domestic corporation, the Reynolds

Court stated "Thus, Alabama’s taxation of domestic

‘Expanded upon at R. 88-96.

10

and foreign corporations does not violate the

Commerce Clause.”

The Taxpayers argue that they submitted

evidence in the trial court that was lacking in Reynolds

Metals that “demonstrates that the franchise tax on

foreign corporations discriminates against them for no

other reason than the state of their incorporation.”

Their evidence consists of a study prepared by

Dr. Richards (Taxpayers’ Exhibit 1) comparing the

amount of taxes actually paid by randomly selected

domestic corporations with the amount they would

-have paid had they been taxed as foreign

corporations. The results purport to prove that the tax

discriminates against foreign corporations.

The Reynolds plaintiffs likewise based their

contention that the tax discriminates against foreign

corporations on data compiled from randomly selected

corporations, which purported to show that foreign

corporations on average paid more taxes than did their

domestic counterparts. The evidence in neither case

overcomes the fact that the taxes for any particular

corporate taxpayer may be higher or lower depending

on its corporate structure and operations when taxed

as either a foreign or a domestic corporation.

The fact that one of the taxpayers in Reynolds

paid significantly less taxes as a foreign than it would

have as a domestic and that most of the Taxpayers in

the present case would pay more taxes as domestic

corporations than they in fact paid as foreign

corporations proves this. The evidence produced in

the present case is very similar to the evidence

produced in Reynolds. It warrants the same result.

11

The Taxpayers emphasize that domestic

corporations can reduce their franchise tax liability by

manipulating the amount of their outstanding shares of

stock, as if foreign corporations do not also minimize

their tax liability by manipulating their tax bases.

However, one of the Taxpayers’ witnesses, Mr.

Richard G. Bacon, testified that although some

corporations have the ability to manipulate the tax that

they would pay by limiting the number of shares that

they issue, very large public corporations do not have

the ability, and that there may be business reasons for

not manipulating the tax base. (R. p. 125-162.) The

Department offers that to the extent that business

considerations allow them to do _ so, _ foreign

corporations can reduce their tax liability by reducing

the capital they employ in Alabama, just as domestic

corporations can reduce their tax liability by reducing

the value of their shares of stock.

Reynolds held that the Alabama franchise tax

does not discriminate against foreign corporations as

applied. However, even if this court finds that the

Taxpayers have proved discrimination, they are not

entitled to prevail in their attack on the constitutionality

of Alabama's franchise tax.

A tax may discriminate against interstate

commerce and still not violate the Commerce Clause.

In order for such a discriminatory tax to be upheld the

State must “show that it advances a legitimate local

purpose that cannot be adequately served by

reasonable, nondiscriminatory alternatives, New

Energy Company of Indiana v. Limbach, 108 S.Ct.

1803, 1810 (1988); or show that the “discrimination is

demonstrably justified by a valid factor unrelated to

12

economic protectionism, Chemical Waste Management

v. Hunt, 112 S.Ct. 2009, 2015 (1992).

The Alabama Supreme Court applied

substantially the above standards in Aeynoids to

uphold the constitutionality of the foreign corporation

franchise tax. The Court stated at page 388:

Even assuming that the lack of uniformity in

the taxes on domestic and foreign

corporations rose to a level of discrimination

that would invoke equal protection or

commerce clause analysis, we would hold that

§40-14-41 does not violate those provisions,

for the following reasons.

The Court went on at pages 388 and 389 to articulate

several legitimate purposes for those statutory

distinctions between foreign and domestic

corporations, which include the mandate of the

Alabama Constitution, ease of regulation and

enforcement, differences in the utilization of State

natural resources between foreign and domestic

corporations, differences in the employment of State

residents and the utilization of State services between

foreign and domestic corporations, and an original

purpose not tu discriminate. Thus even if the present

Taxpayers had proved that Alabama's franchise tax

regime discriminates against foreign corporations, such

discrimination would not violate the Commerce Clause.

The Taxpayers imply that the standard for

determining whether a tax is “compensatory” has been

substantially narrowed since Aeynolds Metals was

decided in 1989. They assert that the holding in that

13

necessary for a valid compensatory

Oregon Waste Systems v. Department

Environmental Quality, 511 U.S. 93, 114 S.Ct. 1345.

128 L.Ed.2d 13 (1994):

2. The tax on interstate commerce must

be shown roughly to approximate--but

not to exceed--the amount of the tax on

intrastate commerce.

3. The events on which the interstate and

intrastate taxes are imposed must be

“substantially equivalent”.

The Taxpayers argue that Alabama cannot satisfy

the second and third criteria of the tax

doctrine. They argue with regard to the second

16

Court adhered closely to the decisions of this Court.

Therefore, there exists no sound reason to issue a writ

certiorari. o

Respectfully submitted

BILL PRYOR

“RON BOWDEN, Counsel

Department of Revenue and Assistant

Attorney Genera!, State of Alabama

DAN E. SCHMAELING, Assistant Counsel

Department of Revenue and Assistant

Attorney General, State of Alabama

P.O. Box 320001

Montgomery, AL 36132-0001

(334) 242-9690

“Counsel of Record for Respondents

July 14, 1998

17

APPENDIX

November 10, 1994

MEMORANDUM

To: Ron Bowden, Chief Counsel

Legal Division

From: Peter M. Petrillo, Jr.

Franchise Tax Division

RE: Modality for ‘As If Domestic’ Analysis

This memorandum is to recap the modality used to

compute the "As If Domestic” analysis (see attachment)

prepared fur counsel in anticipation of the South

Central Bell litigation. The goal of the analysis was to

determine, for the foreign franchise tax years 1986

through 1992, the probable total Alabama domestic

franchise tax and domestic shares tax which would

have been paid had the subject legal entities been

domestic corporations rather than foreign corporations.

FACTS

The legal entities and data from foreign franchise tax

years analyzed were as follows:

1. BellSouth Telecommunications, Inc.

1991 - 1992

Ron J. Bowden, Chief Counsel

November 10, 1994

Page 2

2. BellSouth Corporation

1986 - 1992

3. South Central Bell Telephone Company

1986 - 1992

4. BellSouth Services, Inc.

1986 - 1992

5. BellSouth Financial Services Corporation

1986 - 1992

6. BellSouth Advertising & Publishing Corporation

1986 - 1992

7. BellSouth Resources, Inc.

1989 - 1992

8. BellSouth Products, Inc.

1991 - 1992

9. Alabama Cellular Services, Inc.

1986 - 1992

10. Sunlink Corporation

1986 - 1992

11. TechSouth, Inc.

1986 - 1992

12. CSX Transportation, Inc.

1986 - 1992

The following financial data for each year was taken

from each legal entity's Foreign Franchise Tax Return

as filed.

I. The capital stock (par value) from liability side of

Schedule A - Book Balance Sheet or balance sheet

attached to the return in lieu of completing

Schedule A.

Ron J. Bowden, Chief Counsel

November 10, 1994

Page 3

Il. The total value of all shares of stock (total equity)

from liability side of Schedule A - Book Balance

Sheet or balance sheet attached to the return in

lieu of completing Schedule A.

Ill. The book value of real and tangible personal

property (total capital assets) from asset side of

Schedule A - Book Balance Sheet or balance sheet

attached to the return in lieu of completing

Schedule A.

IV. The book value of goods, wares and merchandise

held for sale (inventories) from asset side of from

Schedule A - Book Balance Sheet or balance sheet

attached to the return in lieu of completing

Schedule A.

V. The cost of capital stock owned in domestic

corporations by the legal entity from Schedule E -

Franchise Tax and Permit Fee Computation (see

exclusion for foreign corporations paying a

franchise tax).

VI. The book value of Alabama real and tangible

property from Schedule B - Alabama Capital Asset

Data.

ASSUMPTIONS

For each legal entity and all franchise tax years, the

following assumptions were made:

A Only the legal entities, BellSouth

Telecommunications, Inc.; South Central Bell

Telephone Company; and CSX Transportation,

Ron J. Bowden, Chief Counsel

November 10, 1994

Page 4

amo ©

Inc., were assumed to be public utilities not

required by Sec. 40-21-29, Code of Alabama 1975,

to list their shares of stock for taxation or to pay ad

valorem taxes on said shares computed pursuant to

Sec. 40-14-70, Code of Alabama 1975.

The Alabama shares tax computations are shown

by the foreign franchise tax year's data used to

compute the tax rather then by the year for which

the amount would be paid. Please note that the

Alabama shares tax for 1990 is based on an ending

balance sheet which occurs prior to October 1, 1989

(e.g., for calendar year accounting periods, the

balance sheet for the year ending December 31,

1988 is used).

The foreign franchise tax liability was assumed to

be the amount as filed.

The domestic franchise tax rate was $10 for each

$1,000 of capital stock.

The minimum domestic franchise tax was $50.

The home or principal office of each legal entity

was assumed for each year to be in Birmingham,

Jefferson County, Alabama, which was the

principal place of business in Alabama listed on

the foreign franchise tax returns.

The total domestic shares millage rate was

determined to be 69.5 mills (6.95%).

1. The state millage rate for Alabama was 6.5

mills (.65%).

2. The county, assumed to be Jefferson County,

millage rate was 35.6 mills (3.56%) reduced by

Ron J. Bowden, Chief Counsel

November 10, 1994

Page 5

a special school tax in Birmingham of 1.1 mills

(.11%).

3. The city, assumed to be Birmingham,

Alabama, millage rate was 28.5 mills (2.85%).

H. Shares of stock are considered to be Class I

I.

personal property and are assessed at 20%.

All legal entities paying an Alabama foreign

franchise tax were assumed to be Alabama

domestic corporations for purposes of the deduction

for costs of domestic capital stock owned by the

legal entity noted in Fact V, above.

The ‘book value of real and tangible personal

property in other states’ was assumed to be the

total ‘book value of real and tangible personal

property’ (see Fact III, above) owned less the ‘book

value of Alabama real and tangible property’ (see

Fact VI, above).

The county assessment was assumed to be 20% of

the ‘book value of Alabama real and tangible

personal property’ (see Fact VI, above).

Some information is not disclosed on the foreign

franchise tax return regarding possible deductions

to the total value of all shares of stock, e.g.,

investment in U.S. government obligations; book

value of air pollution equipment; and book value of

motor vehicles otherwise assessed. These were

assumed to be either zero or already included in

other deductions made in the calculation.

See each attached financial detail schedules for

specific assumptions made for each legal entity.

Ron J. Bowden, Chief Counsel

November 10, 1994

Page 6

Domestic Franchise Tax: The domestic franchise

tax was calculated by multiplying the legal entity's

capital stock by the domestic franchise tax rate ($10

per $1,000 of capital stock), but could not be less than

CALCULATIONS

the minimum tax of $50.

Domestic Shares Tax: The domestic shares tax for

the legal entity was computed by multiplying the

‘residue of total value of stock for assessment’ by the

‘total domestic shares tax millage rate’ (69.5 mills).

i

The ‘total value of all shares of

stock' (see Fact Il, above) was

reduced by deductions for the

‘book value of real and tangible

personal property in other states’

(see Assumption J, above), the

‘book value of goods, wares and

merchandise held for sale’ (see

Fact IV, above), and the ‘cost of

capital stock owned in domestic

corporations’ (see Fact V, above).

The ‘total value of all shares of

stock remaining for assessment’,

was multiplied by the 20% state

assessment rate.

This state assessment amount

was then reduced by the county

assessments to produce the

Ron J Bowden, Chief Counsel

November 10, 1994

Page 7

‘residue of total value of stock for

assessment’.

Attachment

cc: Ernest J. Broadhead, Chief

Louis R. Mills, Assistant Chief

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

BellSouth Telecommunications, Inc. (Q:

11-12-91)

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

~ Total Domestic Corporation Tax 0

Domestic Tax over (under) Foreign Tax 0

BellSouth Corporation

Foreign Corporation: Franchise Tax (As

Paid) 25

Domestic Corporation (As If)

Franchise Tax 3,097,780

Shares Tax 5,307,201

Total Domestic Corporation Tax 8,404,981

Domestic Tax over (under) Foreign Tax 8.404 956

South Central Bell Telephone Company

Foreign Corporation: Franchise Tax (As

Paid) 4,952,697

Domestic Corporation (As If)

Franchise Tax 29,334, 107

Shares Tax 0

Total Domestic Corporation Tax 29,334,107

Domestic Tax over (under) Foreign Tax 24 381.410

Page 1 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1987

BellSouth Telecommunications, Inc. (Q:

11-12-91)

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax 0

Domestic Tax over (under) Foreign Tax 0

BellSouth Corporation

Foreign Corporation: Franchise Tax (As

Paid) 25

Domestic Corporation (As If)

Franchise Tax 3,224,910

Shares Tax 19, 255.869

Total Domestic Corporation Tax 22, 480.779

Domestic Tax over (under) Foreign Tax 22.480. 754

South Central Bell Telephone Company

(M: 12-31-91)

Foreign Corporation: Franchise Tax (As

Paid) 4,995,844

Domestic Corporation (As If)

Franchise Tax 29,489,203

Shares Tax 0

Total Domestic Corporation Tax 29, 489.203

Domestic Tax over (under) Foreign Tax 24 493 359

Page 2 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1988

BellSouth Telecommunications, Inc. (Q:

11-12-91)

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax 0

Domestic Tax over (under) Foreign Tax 0

BellSouth tion

Foreign Corporation: Franchise Tax (As

Paid) 25

Domestic Corporation (As If)

Franchise Tax 4,858,780

Shares Tax 105,638,936

Total Domestic Corporation Tax 110,497,716

Domestic Tax over (under) Foreign Tax 110,497,691

South Centra] Bell Telephone Company

(M: 12-31-91)

Foreign Corporation: Franchise Tax (As

Paid) 4,927,214

Domestic Corporation (As If)

Franchise Tax 29,661,305

Shares Tax 0

Total Domestic Corporation Tax 29,661,305

Page 3 of 32

Summary of Tax Differences in the "As Summary of Tax Differences in the "As

If Domestic” An red

f alysis prepared for If Domestic” Analysis prepared for

counsel in anticipation of South

counsel in anticipation of South

Central Bell case.

a Central Bell case.

ears 1990

Be Telecomm Inc. a

South Te reget ne. (Q BellSouth er am Inc. (Q:

| 1 | eS 1-12-91

Foreign Corporation: Franchise Tax (As Foreign Corporation: Franchise Tax (As

Paid) Paid)

suse amin Domestic Corporation (As If)

Franchise Tax

Franchise Tax

Shares Tax Shares Tax

Total Domestic Corporation Tax 2 Total Domestic Corporation Tax 0

Domestic Tax over (under) Foreign Tax 0 Domestic Tax over (under) Foreign Tax 0

BellSouth tion ;

: — 7 BellSouth Corporation

a Corporation: Franchise Tax (As 9s Foreign Corporation: Franchise Tax (As

| | Paid) | 545

Domestic Corporation (As If) Domestic Corporation (As If)

Franchise Tax 4,859,900

Franchise Tax 4,862,290

Shares Tax 101,254,602 Shares Tax 116,976,429

Total Domestic Corporation Tax 106,114,502 Total Domestic Corporation Tax 121,838,719

Domestic Tax over (under) Foreign Tax = _106.114.477, Domestic Tax over (under) Foreign Tax 121,838,174

South Central mylene ayy Company South Central Bell Telephone Company

Foret Seapets Pranab Wor Ue AM

an” 5.910.566 Foreign Corporation: Franchise Tax (As

| | ald, Paid) 5,334,015

Domestic Corporation (As If) Domestic Corporation (As If)

Franchise Tax 29,846,305

Franchise Tax 30,243,520

Shares Tax 0 Shares Tax 0

Total Domestic Corporation Tax — 29,846,305 Total Domestic Corporation Tax 30,243,520

Domestic Tax over (under) Foreign Tax 24,626,759 Domestic Tax over (under) Foreign Tax 24,909,505

Page 4 of 32 Page 5 of 32

Summary of Tax Differences in the "As

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

BellSouth Telecommunications, Inc. (Q:

11-12-91)

1992

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

BellSouth Corporation

6,371,607

73, 189,591

0

73, 189,591

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1991

BellSouth Telecommunications, Inc. (Q:

11-12-91)

Foreign Corporation: Franchise Tax (As

Paid) 25

Domestic Corporation (As If)

Franchise Tax 42,946,058

Shares Tax 0

Total Domestic Corporation Tax 42,946,058

Domestic Tax over (under) Foreign Tax 42 946,033

BellSouth Corporation

Foreign Corporation: Franchise Tax (As

Paid) 25

Domestic Corporation (As If)

Franchise Tax 4,866,470

Sheres Tax 110,064,056

Total Domestic Corporation Tax 114,930,526

Domestic Tax over (under) Foreign Tax 114,930,501

South Central Bell Telephone Company

(M: 12-31-91)

Foreign Corporation: Franchise Tax (As

Paid) 5,210,339

Domestic Corporation (As If)

Franchise Tax 30,243,523

Shares Tax 0

Total Domestic Corporation Tax 30,243,523

Domestic Tax over (under) Foreign Tax 25.033. 184

Page 6 of 32

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

South Central Bell Telephone Company

(M: 12-31-91)

66,817,984

5,311

4,482,870

24,314,649

29,197,519

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

Page 7 of 32

29,192,208

se

% |[Slo8

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

Total

BellSouth Telecommunications, Inc. (Q:

11-12-91)

Foreign Corporation: Franchise Tax (As

Paid) 6,371,632

Domestic Corporation (As If)

Franchise Tax 116, 135,649

Shares Tax 0

Total Domestic Corporation Tax 116,135,649

Domestic Tax over (under) Foreign Tax 109,764,017

BellSouth Corporation

Foreign Corporation: Franchise Tax (As

Paid) 5,981

Domestic Corporation (As If)

Franchise Tax 30,653,000

Shares Tax 482,811,742

Total Domestic Corporation Tax 513,464,742

Domestic Tax over (under) Foreign Tax 513,458,761

South Central Bell Telephone Company

(M: 12-31-91)

Foreign Corporation: Franchise Tax (As

Paid) 30,639,680

Domestic Corporation (As If)

Franchise Tax 178,818,013

Shares Tax 0

Total Domestic Corporation Tax 178,818,013

Domestic Tax over (under) Foreign Tax 148 178,333

Page 8 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1986

BellSouth Services, Inc. (M:

12-31-91)

Foreign Corporation: Franchise Tax (As

Paid) 30,950

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 340,524

Total Domestic Corporation Tax 340,574

Domestic Tax over (under) Foreign Tax 309.624

BellSouth Financial Services Corporation

Foreign Corporation: Franchise Tax (As

Paid) 25

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 0

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax 25

BellSouth Advertising & Publishing

Corporation

Foreign Corporation: Franchise Tax (As

Paid) 60,038

Domestic Corporation (As If)

Franchise Tax 1,825,840

Shares Tax 2,400,780

Total Domestic Corporation Tax 4,226.620

Domestic Tax over (under) Foreign Tax 4, 166,582

Page 9 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1987

BellSouth Services, Inc. (M:

12-31-91)

Foreign Corporation: Franchise Tax (As

Paid) 108,774

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 0

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax -108,724

BellSouth Financial Services Corporation

Foreign Corporation: Franchise Tax (As

Paid) 25

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 0

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax 25

BellSouth Advertising & Publishing

Corporation

Foreign Corporation: Franchise Tax (As

Paid) 59,922

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 2,386,777

Total Domestic Corporation Tax 2,386,827

Domestic Tax over (under) Foreign Tax 2 326.905

Page 10 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1988

BellSouth Services, Inc. (M:

12-31-91)

Foreign Corporation: Franchise Tax (As

Paid) 139,893

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 0

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax - 139,843

BellSouth Financial Services Corporation

Foreign Corporation: Franchise Tax (As

Paid) 25

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 0

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax 25

BellSouth Advertising & Publishing

Corporation

Foreign Corporation: Franchise Tax (As

Paid) 55,586

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 2,395,401

Total Domestic Corporation Tax 2,395,451

Domestic Tax over (under) Foreign Tax 2,339,865

——

Page 11 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1989

BellSouth Services, Inc. (M:

12-31-91)

Foreign Corporation: Franchise Tax (As

Paid) 135,610

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 0

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax -135,560

BellSouth Financial Services Corporation

Foreign Corporation: Franchise Tax (As

Paid) 130,334

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 0

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax - 130.284

BellSouth Advertising & Publishing

Corporation

Foreign Corporation: Franchise Tax (As

Paid) 56,659

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 2,775,518

Total Domestic Corporation Tax 2,775,568

Domestic Tax over (under) Foreign Tax 2.718.909

Page 12 of 32

Page 13 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1990

BellSouth Services, Inc. (M:

12-31-91)

Foreign Corporation: Franchise Tax (As

Paid) 205,525

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 0

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax -205,475

BellSouth Financial Services Corporation

Foreign Corporation: Franchise Tax (As

Paid) 16,908

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 39,657

Total Domestic Corporation Tax 39,707

Domestic Tax over (under) Foreign Tax 22.799

BellSouth Advertising & Publishing

Corporation

Foreign Corporation: Franc. ise Tax (As

Paid) 71,861

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 3,542,548

Total Domestic Corporation Tax 3,542 598

Domestic

Tax over (under) Foreign Tax 3, 470, 737

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1991

BellSouth Services, Inc. (M:

12-31-91)

Foreign Corporation: Franchise Tax (As

Paid) 206, 333

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 0

50

283

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax -206,

BellSouth Financial Services Corporation

Foreign Corporation: Franchise Tax (As

Paid) 28,539

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 139,737

Total Domestic Corporation Tax 139,787

Domestic Tax over (under) Foreign Tax 111,248

BellSouth Advertising & Publishing

tion

Foreign Corporation: Franchise Tax (As

Paid) 75,421

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 143,354

Total Domestic Corporation Tax 4,143,404

Domestic Tax over (under) Foreign Tax 4,067,983

Page 14 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1992

BellSouth Services, Inc. (M:

12-31-91)

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

25

50

0

50

Domestic Tax over (under) Foreign Tax 25

et

BellSouth Financial Services Corporation

Foreign Corporation: Franchise Tax (As

Paid) 17,172

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 155,221

Total Domestic Corporation Tax 155,271

Domestic Tax over (under) Foreign Tax 138,099

BellSouth Advertising & Publishing

Foreign Corporation: Franchise Tax (As

Paid) 65,829

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 4,557,719

Total Domestic Corporation Tax 4,557,769

Domestic Tax over (under) Foreign Tax 4,491,940

Page 15 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Beli case.

Total

BellSouth Services, Inc. (M:

12-31-91)

Foreign Corporation: Franchise Tax (As

Paid) 827.110

Domestic Corporation (As If)

Franchise Tax 350

Shares Tax 340,524

Total Domestic Corporation Tax 340,874

Domestic Tax over (under) Foreign Tax -486, 236

BellSouth Financial Services Corporation

Foreign Corporation: Franchise Tax (As

Pia 193,028

Domestic Corporation (As If)

Franchise Tax 350

Shares Tax 615

Total Domestic Corporation Tax 334,965

Domestic Tax over (under) Foreign Tax 141,937

BellSouth Advertising & Publishing

Corporation

Foreign Corporation: Franchise Tax (As

Paid) 445,316

Domestic Corporation (As If)

Franchise Tax 1,826, 140

Shares Tax 22,202,097

Total Domestic Corporation Tax 24,028, 237

Domestic Tax over (under) Foreign Tax 23,582,921

Page 16 of 32

BellSouth Inc.

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

BellSouth Products. Inc.

Foreign Corporation: Franchise Tax (As

Paid) ‘

Domestic Corporation (As If)

Franchise Tax

Shares Tax

1986

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

Alabama Cellular Services. Inc.

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

Page 17 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

BellSouth Resources, Inc.

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

BellSouth Products. Inc.

1987

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

Alabama Cellular ices, Inc.

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

Page 18 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1988

Foreign Corn resources. Ine

F tion: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

BellSouth Products. Inc.

0

oe |

ag Corporation: Franchise Tax (As

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

Alabama Cellular Services. Inc.

Oo

oO

—_—_abama Cellular Services. |

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

Page 19 of 32

43,602

|

i}

:

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

BellSouth Resources, Inc.

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

BellSouth Products. Inc.

1989

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

Alabama Cellular Serv: Inc.

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

Page 20 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

BellSouth Resources. Inc.

a Corporation: Franchise Tax (As

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

BellSouth Products, Inc.

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

1990

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

_Alabama Cellular Services. Inc.

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

Page 21 of 32

—_—_-—___ -—____ —-

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1991

BellSouth Resources, Inc.

Foreign Corporation: Franchise Tax (As

Paid) 2.720

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 30,177

Total Domestic Corporation Tax 30,227

Domestic Tax over (under) Foreign Tax 27,507

BellSouth Products, Inc.

Foreign Corporation: Franchise Tax (As

Paid) 5,147

Domestic Corporation (As If) ne

Franchise Tax 50

Shares Tax 0

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax -3,097

Alabama Cellular Services, Inc.

Foreign Corporation: Franchise Tax (As

Paid) 64,880

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 105,710

Total Domestic Corporation Tax 105,760

Domestic Tax over (under) Foreign Tax 40,880

Page 22 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

BellSouth Inc.

naa Corporation: Franchise Tax (As

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

BellSouth Products. Inc.

1992

a Corporation: Franchise Tax (As

aid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

Page 23 of 32

Foreign Corporation: Franchise Tax (As

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

Total

BellSouth Resources, Inc.

Foreign Corporation: Franchise Tax (As

Paid) 7,608

Domestic Corporation (As If)

Franchise Tax 200

Shares Tax 86,688

Total Domestic Corporation Tax 86,888

Domestic Tax over (under) Foreign Tax 79,280

BellSouth Products, Inc.

Foreign Corporation: Franchise Tax (As

Paid) 3,172

Domestic Corporation (As If)

Franchise Tax 100

Shares Tax 0

Total Domestic Corporation Tax 100

Domestic Tax over (under) Foreign Tax -3,072

Alabama Cellular Services, Inc.

Foreign Corporation: Franchise Tax (As

Paid) 304,268

Domestic Corporation (As If)

Franchise Tax 350

Shares Tax 264,678

Total Domestic Corporation Tax 265,028

Domestic Tax over (under) Foreign Tax -39,240

Page 24 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1986

Sunlink Corporation

Foreign Corporation: Franchise Tax (As

Paid) 10,939

Domestic Corporation (As If)

Franchise Tax 113,670

Shares Tax | 12.176

Total Domestic Corporation Tax 125.846

Domestic Tax over (under) Foreign Tax 114,907

TechSouth, Inc.

Foreign Corporation: Franchise Tax (As

Paid) 4,242

Domestic Corporation (As If)

Franchise Tax 1,025

Shares Tax 22, 367

Total Domestic Corporation Tax 23,392

Domestic Tax over (under) Foreign Tax 19,150

555,951

Domestic Corporation (As If)

Franchise Tax 2,292,208

Shares Tax sin 0

Total Domestic Corporation Tax 2,292,208

Domestic Tax over (under) Foreign Tax 1,736,257

Total Domestic Tax over (under)

Foreign Tax

Page 25 of 32

39,117,756

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1987

Sunlink Corporation

Foreign Corporation: Franchise Tax (As

Paid) 6,776

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 33,541

Total Domestic Corporation Tax 33,591

Domestic Tax over (under) Foreign Tax 26.815

TechSouth, Inc.

Foreign Corporation: Franchise Tax (As

Paid) | 4,756

Domestic Corporation (As If)

Franchise Tax 1,015

Shares Tax 15,689

Total Domestic Corporation Tax 16,704

Domestic Tax over (under) Foreign Tax 11,948

557,066

Domestic Corporation (As If)

Franchise Tax 2,172,208

Shares Tax 0

Total Domestic Corporation Tax 2,172,208

Domestic Tax over (under) Foreign Tax 1.615, 142

Total Domestic Tax over (under)

Foreign Tax een 0,834,052,

Page 26 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1988

i tion

Foreign Toes Franchise Tax (As

Paid) 5.840

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 0

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax -5,790

a TechSouth, Inc.

Foreign Corporation: Franchise Tax (As

Paid) 4,835

Domestic Corporation (As If)

Franchise Tax 1,015

Shares Tax 0

Total Domestic Corporation Tax 1,015

Domestic Tax over (under) Foreign Tax -3,820

Sse Trepepcrtation, ine.

Paid) 570,472

Domestic Corporation (As If)

Franchise Tax 2,452,208

Shares Tax 0

Total Domestic Corporation Tax 2,452,208

Domestic Tax over (under) Foreign Tax 1,881,736

Total Domestic Tax over (under)

Foreign Tax ew 39,285,955,

Page 27 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1989

Sunlink tion

Foreign Corporation: Franchise Tax (As

Paid) 7,769

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 0

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax -7,719

TechSouth, Inc.

Foreign Corporation: Franchise Tax (As

Paid) 2.753

Domestic Corporation (As If)

Franchise Tax 1,015

Shares Tax 3,597

Total Domestic Corporation Tax 4612

Domestic Tax over (under) Foreign Tax 1,859

——SSSSSSS

Paid) 574,252

Domestic Corporation (As If)

Franchise Tax 1,845,540

Shares Tax 0

Total Domestic Corporation Tax 1,845,540

Domestic Tax over (under) Foreign Tax 1,271,288

Total Domestic Tax over (under)

Foreign Tax nt 4, 460,504

Page 28 of 32 ~

Foreign Tax

Page 29 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1990

Sunlink Corporation

Paid) 37,952

Domestic Corporation (As If)

Franchise Tax 50

Shares Tax 9.480

Total Domestic Corporation Tax 9,530

Domestic Tax over (under) Foreign Tax 28,422

TechSouth. Inc.

Foreign Corporation: Franchise Tax (As

Paid) | 3.610

Domestic Corporation (As If)

Franchise Tax 980

Shares Tax 0

Total Domestic Corporation Tax 980

Domestic Tax over (under) Foreign Tax -2,630

a eee

Paid) 573,792

Domestic Corporation (As If)

Franchise Tax 1,812,208

Shares Tax 0

Total Domestic Corporation Tax 1,812,208

Domestic Tax over (under) Foreign Tax 416

Total Domestic Tax over (under)

951

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

1991

Sunhnk tion

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

24,108

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

TechSouth, Inc.

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax -Liis

CSX Treneportanon, Ing.

Paid) 571,327

Domestic Corporation (As If)

Franchise Tax 1,812,208

Shares Tax 0

Total Domestic Corporation Tax 1,812,208

Domestic Tax over (under) Foreign Tax

Total Domestic Tax over (under)

Foreign Tax

Page 30 of 32

1,240,881

188, 163,006

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

Sunhnk Corporation _

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

TechSouth. Inc.

15,199

Foreign Corporation: Franchise Tax (As

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

hs Trepeportation, ine.

Paid)

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Zio S &

Domestic Tax over (under) Foreign Tax 1244 262

Total Domestic Tax over (under)

Foreign Tax

Page 31 of 32

Summary of Tax Differences in the "As

If Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

Total

Sunlink tion

Foreign Corporation: Franchise Tax (As

Paid) 108,583

Domestic Corporation (As If)

Franchise Tax 113,970

Shares Tax 55,197

Total Domestic Corporation Tax 169, 167

Domestic Tax over (under) Foreign Tax 60,584

TechSouth, Inc.

Foreign Corporation: Franchise Tax (As

Paid) 22,974

Domestic Corporation (As If)

Franchise Tax 6,080

Shares Tax 41,653

Total Domestic Corporation Tax 47,733

Domestic Tax over (under) Foreign Tax 24 759

Domestic Corporation (As If)

Franchise Tax

Shares Tax

Total Domestic Corporation Tax

Domestic Tax over (under) Foreign Tax

Total Domestic Tax over (under)

Foreign Tax

Page 32 of 32

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1986

BellSouth Telecommunications, Inc.

(Q: 11-12-91)

‘Foreign Corporation: Franchise Tax Gs

Paid)

Domestic Corporation (As If)

api

D 1: Franchise T,

Domestic Shares Tax:

Total value of all shares of stock

Deductions:

Book value of real & tangible personal

property

Book value of Alabama real & tangible

personal property

Book value of real & tangible personal

property in other states

Book value of merchandise held for sale

Cost of domestic capital stock owned

Total deductions

Total value of all shares of stock

remaining for assessment

State assessment (not less than zero)

County assessments

Residue of total value of stock for

0

0

_————————_____—____—__ ___4

0

0

assessment (not < 0) 0

N/A Domestic Shares Tax NiO |

. . SSSS==

Total Domestic Corporation Tax 0

Domestic Tax over (under) Foreign Tax 0

——————

Page 1 of 88

Financial Data and Calculations Financial Data and Calculations

used in "As If Domestic” Analysis used in "As If Domestic” Analysis

prepared for counsel in anticipation prepared for counsel in anticipation

of South Central Bell case. of South Central Bell case.

1987 1988

BellSouth Telecommunications, Inc. BellSouth Telecommunications, Inc.

(Q: 11-12-91) (Q: 11-12-91)

Foreign Corporation: Franchise Tax (As ‘Foreign Corporation: Franchise Tax (As

Domestic Corporation (As If) Domestic Corporation (As If) BRC we

Capital Stock ——— Capital Stock

Domestic Franchise Tax CEN | Domestic Franchise Tax PCRGINAENE |

Domestic Shares Tax: Domestic Shares Tax:

Total value of all shares of stock Total value of all shares of stock

Deductions: Deductions:

Book value of real & tangible personal Book value of real & tangible personal

property property

Book value of Alabama real & tangible Book value of Alabama real & tangible

personal property personal property

Book value of real & tangible personal Book value of real & tangible personal

property in other states 9 property in other states 0

Book value of merchandise held for sale Book value of merchandise held for sale

Cost of domestic capital stock owned Cost of domestic capital stock owned

Total deductions v Total deductions 0

Total value of all shares of stock Total value of all shares of stock

remaining for assessment iil ta remaining for assessment 0

State assessment (not less than zero) 0 State assessment (not less than zero) 0

County assessments 0 County assessments 0

Residue of total value of stock for Residue of total value of stock for

assessment (not < 0) Sa assessment (not < 0) 0

N/A Domestic Shares Tax 0 N/A Domestic Shares Tax CRE |

, o ’ ° T. 0 Ti l D . » ‘ Ti FEE

————————————

Domestic Tax over (under) Foreign Tax _ =F. Domestic Tax over (under) Foreign Tax 0

Page 2 of 88 Page 3 of 88

Financial Data and Calculations Financial Data and Calculations

used in "As If Domestic” Analysis used in "As If Domestic” Analysis

prepared for counsel in anticipation prepared for counsel in anticipation

of South Central Bell case. of South Central Bell case.

1989 1990

BellSouth Telecommunications, Inc. BellSouth Telecommunications, Inc.

(Q: 11-12-91) (Q: 11-12-91)

Foreign Corporation: Franchise Tax (As ‘Foreign Corporation: Franchise Tax (As

Paid) saineitieniaiittiaaaiiaiaiiate Paid) tae

Domestic Corporation (As If) Domestic Corporation (As If)

Capital Stock Capital Stock

P ° eve ycaes | . ‘ SS

Domestic Shares Tax: Domestic Shares Tax: sete i a os ral

Total value of all shares of stock Total value of all aii of stock

Deductions: Deductions:

Book value of real & tangible personal Book value of real & tangible personal

property property

Book value of Alabama real & tangible Book value of Alabama real & tangible

personal property al

Book value of real & tangible personal bate Nagge ai & tangible personal

property in other states 0 property in other states 0

Book value of merchandise held for sale Book value of merchandise held for sale

Cost of domestic capital stock owned Cost of domestic capital stock owned

Total deductions 0 Total deductions 0

Total value of all shares of stock Total value of all shares of stock

remaining for assessment ees | remaining for assessment 0

State assessment (not less than zero) 0 State assessment (not less than zero) 0

County assessments 0

Residue of total value of stock for ale roll of stock for °

assessment (not < 0) 0 assessment (not < 0) 0

N/A Domestic Shares Tax 0 N/A Domestic Shares Tax 0

. - T PrIREE ON: | ‘ ‘ eae ae

Domestic Tax over (under) Foreign Tax See | Domestic Tax over (under) Foreign Tax 0

Page 4 of 88 Page 5 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1991

BellSouth Telecommunications, Inc.

(Q: 11-12-91)

Foreign Corporation: Franchise Tax (As

Paid) 25

Domestic Corporation (As If)

Capital Stock 4,294,605,803

Domestic Franchise Tax 42,946,058

Domestic Shares Tax:

Total value of all shares of stock 6,604,398,291

Deductions:

Book value of real & tangible personal

property 20,216,506,645

Book value of Alabama real & tangible

personal property 0

Book value of real & tangible personal

property in other states 20,216,506,645

Book value of merchandise held for sale 152,915,582

Cost of domestic capital stock owned 89,710,333

Total deductions 20,459, 132,560

Total value of all shares of stock

remaining for assessment -13,854,734,269

State assessment (not less than zero) 0

County assessments 0

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax Manes |

Total Domestic Corporation Tax 42,946,058

Domestic Tax over (under) Foreign Tax 42,946.033

Page 6 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1992

BellSouth Telecommunications, Inc.

(Q: 11-12-91)

‘Foreign Corporation: Franchise Tax (As

Paid) 6,371,607

Domestic Corporation (As If)

Capital Stock 7,318,959, 147

Domestic Franchise Tax 73,189,591

Domestic Shares Tax:

Total value of all shares of stock 11,653,592,076

Deductions:

Book value of real & tangible personal

property 37.213,279,384

Book value of Alabama real & tangible

personal property -3,760,348,233

Book value of real & tangible personal

property in other states 33,452,931,151

Book value of merchandise held for sale

Cost of domestic capital stock owned

Total deductions .

Total value of all shares of stock

remaining for assessment

State assessment (not less than zero)

County assessments

Residue of total value of stock for

assessment (not < 0)

N/A Domestic Shares Tax

Total D iC ‘on T

Domestic Tax over (under) Foreign Tax

Page 7 of 88

0

0

33,452,931,151

-21,799,339.075

0

-752,069,647

-752,069,647

0

73,189,591

66,817,984

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1986

BellSouth corpora

oreign Corporation: Franchise Tax (As

Paid) 25

Domestic Corporation (As If)

Capital Stock 309,778,000

Domestic Franchise Tax 3,097,780

Domestic Shares Tax:

Total value of all shares of stock 10, 198,051,000

Deductions:

Book value of real & tangible personal

property 6,650,000

Book value of Alabama real & tangible

personal property 0

Book value of real & tangible personal

property in other states 6,650,000

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 9,809,588,000

Total deductions 9,816,238,000

Total value of all shares of stock

remaining for assessment 381,813,000

State assessment (not less than zero) 76,362,600

County assessments 0

Residue of total value of stock for

assessment (not < 0) 76,362,600

N/A Domestic Shares Tax 5,307,201

Total Domestic Corporation Tax 8,404,981

Domestic Tax over (under) Foreign Tax 8,404,956

Page 8 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1987

———— ——

oreign ration: Franc ax

Paid) 25

Domestic Corporation (As If)

Tapital Stock 322,491,000

Domestic Franchise Tax ee 224,910

Domestic Shares Tax:

Total value of all shares of stock 11,264,638,000

Deductions:

Book value of real & tangible personal

property 10,250,000

Book value of Alabama real & tangible

personal property 0

Book value of real & tangible personal

property in other states 10,250,000

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 9,869,073,672

Total deductions 9.879,323,672

Total value of all shares of stock

remaining for assessment 1,385,.314,328

State assessment (not less than zero) 277,062,866

County assessments 0

Residue of total value of stock for

assessment (not < 0) 277,062,866

N/A Domestic Shares Tax 19,255,869

Total Domestic Corporation Tax 22, 480.779

Domestic Tax over (under) Foreign Tax 22 480.754

Page 9 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1988

oreign Corporation: ax (/

Paid) 25

Domestic Corporation (As If)

Tapital Stock 485,878,000

Domestic Franchise Tax 4,858,780

Domestic Shares Tax:

Total value of all shares of stock 11,978,413,000

Deductions:

Book value of real & tangible personal

property 9,733,000

Book value of Alabama real & tangible

personal property 0

Book value of real & tangible personal

property in other states 9,733,000

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 4,368,756,571

Total deductions 4.378, 489.571

Total value of all shares of stock

remaining for assessment 7,599,923,429

State assessment (not less than zero) 1,519,984,686

County assessments 0

Residue of total value of stock for

assessment (not < 0) 1,519,984 .686

N/A Domestic Shares Tax 105,638,936

— ===

Total Domestic Corporation Tax 110,497,716

Domestic Tax over (under) Foreign Tax 110,497,691

Page 10 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1989

ee

oreign Corporation: ax

Paid) 25

Domestic Corporation (As If)

Capital Stock = 485,990,000

Domestic Franchise Tax 4.859.900

Domestic Shares Tax:

Total value of all shares of stock 11,840,689,000

Deductions:

Book value of real & tangible personal

property 22,458,000

Book value of Alabama real & tangible

personal property 0

Book value of real & tangible personal

property in other states 22,458,000

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 4,533,727,252

Total deductions 4.556, 185,252

Total value of all shares of stock

remaining for assessment 7,284,503,748

State assessment (not less than zero) 1,456,900,750

County assessments 0

Residue of total value of stock for

assessment (not < 0) 1.456 900,750

N/A Domestic Shares Tax 101,254,602

Total Domestic Corporation Tax 106,114,502

Domestic Tax over (under) Foreign Tax 106,114,477

eee

Page 11 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1990

——eeEee

oreign Corporation: Fran ax

Paid) 545

Domestic Corporation (As If)

Tapital Stock 486, 229.000

Domestic Franchise Tax 862.290

Domestic Shares Tax:

Total value of all shares of stock 13, 103,506,000

Deductions:

Book value of real & tangible personal

property 18,058,000

Book value of Alabama real & tangible

personal property -23,804

Book value of real & tangible personal

property in other states 18,034, 196

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 4,669,877 587

Total deductions 4.687,911,783

Total value of all shares of stock

remaining for assessment 8.415.594,217

State assessment (not less than zero) 1,683, 118,843

County assessments -4,761

Residue of total value of stock for

assessment (not < 0) 1,683, 114,082

N/A Domestic Shares Tax 116,976,429

———_—__ —___ __ ~_ ______4

Total Domestic Corporation Tax 121,838,719

Domestic Tax over (under) Foreign Tax 121 838, 174

Page 12 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1991

BellSouth Corporation

Foreign Corporation. oer Tax (As

Paid) 25

Domestic Corporation (As If)

Capital Stock 486 647,037

Domestic Franchise Tax __ 4,866,470

Domestic Shares Tax:

Total value of all shares of stock 12,671,762,633

Deductions:

Book value of real & tangible personal

property 17,194,131

Book value of Alabama real & tangible

personal property -20,339

Book value of real & tangible personal

property in other states 17,173,792

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 4.736,291,092

Total deductions 4.753,464,884

Total value of all shares of stock

remaining for assessment 7,918,297,749

State assessment (not less than zero) 1,583,659,550

County assessments -4,068

Residue of total value of stock for

assessment (not < 0) 1.583.655 482

N/A Domestic Shares Tax 110,064,056

Total Domestic Corporation Tax 114,930,526

Domestic Tax over (under) Foreign Tax 114,930,501

Page 13 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1992

oreign Corporation: ise lax

Paid) 5,311

Domestic Corporation (As If)

Tapital Stock | 488,286,956

Domestic Franchise Tax 4,882,870

Domestic Shares Tax:

Total value of all shares of stock 13,115,856,792

Deductions:

Book value of real & tangible personal

property 15,707,665

Book value of Alabama real & tangible

personal property -31,606

Book value of real & tangible personal

property in other states 15,676,059

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 11,350,893,834

Total deductions 11,366,569,893

Total value of all shares of stock

remaining for assessment 1,749,286, 899

State assessment (not less than zero) 349,857,380

County assessments -6,321

Residue of total value of stock for

assessment (not < 0) 349,851,059

N/A Domestic Shares Tax 24,314,649

Total Domestic Corporation Tax 29,197,519

Domestic Tax over (under) Foreign Tax 29,192,208

Page 14 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1986

South Central Bell Telephone

hee

oreign Corporation: ax

Paid) 4.952 697

Domestic Corporation (As If)

ee ee

ap! . 2.933 410.688

Domestic Franchise Tax 29,334,107

Domestic Shares Tax:

Total value of all shares of stock 4,657,099,274

Deductions:

Book value of real & tangible personal

property 11,896,494,229

Book value of Alabama real & tangible

personal property -2,572,569,291

Book value of real & tangible personal

property in other states 9,323,924,938

Book value of merchandise held for sale 104,949,072

Cost of domestic capital stock owned 26,798,466

Total deductions 9.455,672,.476

Total value of all shares of stock

remaining for assessment -4.798, 573.202

State assessment (not less than zero) 0

County assessments -514,513,858

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax 0

Total Domestic Corporation Tax 29,334,107

Domestic Tax over (under) Foreign Tax 24,381,410

(sect

Page 15 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1987

South Central Bell Telephone

Com (M: 12-31-91)

Foreign Coneraton Franchise Tax (As

Paid) 4.995, 844

Domestic Corporation (As If)

Tapital Stock 2,948,920, 303

Domestic Franchise Tax 29, 489 203

Domestic Shares Tay:

Total value of all shares of stock 4,666,716,143

Deductions:

Book value of real & tangible personal

property 12,661,318,891

Book value of Alabama real & tangible

personal property -2,765,244,707

Book value of real & tangible personal

property in other states 9,896,074, 184

Book value of merchandise held for sale 103,779,963

Cost of domestic capital stock owned 42,840,118

Total deductions 10,042,694,265

Total value of all shares of stock

remaining for assessment -5.375,978,122

State assessment (not less than zero) 0

County assessments -553,048,941

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax 0

Total Domestic Corporation Tax 29, 489.203

Domestic Tax over (under) Foreign Tax 24 493,359

Page 16 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1988

South Central Bell Telephone

eee

oreign Corporation: Franc ax (As

Paid) 4,927,214

Domestic Corporation (As If)

Capital Stock 2,966, 130,486

Domestic Franchise Tax 29,661,305,

Domestic Shares Tax:

Total value of all shares of stock 4,650,522,281

Deductions:

Book value of real & tangible personal

property 13,314,381,056

Book value of Alabama real & tangible

personal property -2,947,644, 193

Book value of real & tangible personal

property in other states 10,366,736,863

Book value of merchandise held for sale 54,476,399

Cost of domestic capital stock owned 80,263,546

Total deductions 10,501,476,808

Total value of all shares of stock

remaining for assessment -5,850,954,527

State assessment (not less than zero) 0

County assessments -589,528,839

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax 0

Total Domestic Corporation Tax 29,661,305

Domestic Tax over (under) Foreign Tax 24 734,091

Page 17 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1989

South Central Bell Telephone

Company (M: 12-31-91)

Foreign Conraton Franchise Tax (As

Paid) 5,219,546

Domestic Corporation (As If)

Capital Stock 2,984,630,486

Domestic Franchise Tax 29,846,305

Domestic Shares Tax:

Total value of all shares of stock 4,989,517,462

Deductions:

Book value of real & tangible personal

property 14,040, 125,535

Book value of Alabama real! & tangible

personal property -3,149,410,759

Book value of real & tangible personal

property in other states 10,890,7 14,776

Book value of merchandise held for sale 58,557,238

Cost of domestic capital stock owned 118,059, 135

Total deductions 11,067,331,149

Total value of all shares of stock

remaining for assessment -6,077,813,687

State assessment (not less than zero) 0

County assessments -629,882,152

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax 0

Total Domestic Corporation Tax 29,846,305

Domestic Tax over (under) Foreign Tax 24,626,759

Page 18 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1990

South Central Bell Telephone

TORIgT CoS rahe

oreign Corporation: Franchise Tax (As

Paid) 5,334,015

Domestic Corporation (As If)

Capital Stock 3,024, 352,000

Domestic Franchise Tax 30,243,520

Domestic Shares Tax:

Total value of all shares of stock 6,349,956,000

Deductions:

Book value of real & tangible personal

property 9,345,291,000

Book value of Alabama real & tangible

personal property -2,132,.931,837

Book value of real & tangible personal

property in other states 7,212,359, 163

Book value of merchandise held for sale 83,962,678

Cost of domestic capital stock owned 122,495,930

Total deductions 7,418,817,771

Total value of all shares of stock

remaining for assessment -1,068,861,771

State assessment (not less than zero) 0

County assessments -426 586,367

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax 0

Total Domestic Corporation Tax 30,243,520

Domestic Tax over (under) Foreign Tax 24 909.505

Page 19 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1991

South Central Bell Telephone

Company (M: 12-31-91)

oreign Corporation: Franchise Tax (As

Paid) 5,210,339

Domestic Corporation (As If)

Capital Stock 3,024, 352,334

D - Franchise T;

Domestic Shares Tax:

Total value of all shares of stock

Deductions:

Book value of real & tangible personal

property

Book value of Alabama real & tangible

personal property

Book value of real & tangible personal

property in other states

Book value of merchandise held for sale

Cost of domestic capital stock owned

Total deductions

Total value of all shares of stock

remaining for assessment

State assessment (not less than zero)

County assessments

Residue of total value of stock for

assessment (not < 0)

N/A Domestic Shares Tax

Total D cC ration T.

Domestic Tax over (under) Foreign Tax

Page 20 of 88

30,243,523

4,808,691,276

9,379,448,000

-2,158, 146,454

7,221,301,546

80,193,000

89.709,883

7,391,204,429

-2,582,513,153

0

-431,629,291

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1992

South Central Bell Telephone

Company (M: 12-31-91)

Foreign eOSATIIEE Franchise Tax (As

Paid) 25

Domestic Corporation (As If)

Capital Stock 0

D - Franchise T;

Domestic Shares Tax:

Total value of all shares of stock

Deductions:

Book value of real & tangible personal

property

Book value of Alabama real & tangible

persona! property

Book value of real & tangible personal

property in other states

Book value of merchandise held for sale

Cost of domestic capital stock owned

Total deductions

Total value of all shares of stock

remaining for assessment

State assessment (not less than zero)

County assessments

Residue of total value of stock for

assessment (not < 0)

N/A Domestic Shares Tax

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax 25

Page 21 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1986

BellSouth Services, Inc.

(M: 12-31-91)

oreign Corporation: Franchise Tax (:

Paid) 30,950

Domestic Corporation (As If)

Capital Stock 500

D -- Franchise T a

Domestic Shares Tax:

Total value of all shares of stock 29,938,327

Deductions:

Book value of real & tangible personal

property 5,440,206

Book value of Alabama real & tangible

personal property -41,279

Book value of real & tangible personal

property in other states 5,398,927

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 5,398,927

Total value of all shares of stock

remaining for assessment 24 539,400

State assessment (not less than zero) 4,907,880

County assessments -8,256

Residue of total value of stock for

assessment (not < Q) 4,899,624

N/A Domestic Shares Tax 340,524

Total Domestic Corporation Tax 340,574

Domestic Tax over (under) Foreign Tax 309.624

Page 22 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1987

BellSouth Services, Inc.

x 12-31-91)

oreign Corporation: ax (

Paid)

Domestic Corporation (As If)

Tapital Stock

D - Franchise T,

Domestic Shares Tax:

Total value of all shares of stock

Deductions:

Book value of real & tangible personal

property

Book value of Alabama real & tangible

personal property

Book value of real & tangible personal

property in other states

Book value of merchandise held for sale

Cost of domestic capital stock owned

Total deductions

80.009 466

Total value of all shares of stock

remaining for assessment

-38, 706,966

State assessment (not less than zero) 0

County assessments -2,215,307

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax 0

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax -108,724

Page 23 of 88

Financial Data and Calculations

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1988

BellSouth Services, Inc.

(M: 12-31-91)

oreign Corporation: Franchise Tax (:

Paid) 139,893

Domestic Corporation (As If)

Tapital Stock 500

D oF hise T a

Domestic Shares Tax:

Total value of all shares of stock 93,070,387

Dedwetions:

Book value of real & tangible personal

property 98,435,000

Book value of Alabama real & tangible

personal property - 18,632,301

Book value of real & tangible personal

property in other states 79,802,699

Book value of merchandise held for sale 101,448,000

Cost of domestic capital stock owned 0

Total deductions 181,250,699

Total value of all shares of stock

remaining for assessment -88, 180,312

State assessment (not less than zero) 0

County assessments 3,726,460

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax RON TEREST |

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax -139,843

Page 24 of 88

1989

BellSouth Services, Inc.

tt 12-31-91)

oreign Corporation: ax

Paid) 135,610

Domestic Corporation (As If)

Capital Stock = — 500

Domestic Franchise Tax 50

Domestic Shares Tax:

Total value of all shares of stock 93,845,376

Deductions:

Book value of real & tangible personal

property 112,985,469

Book value of Alabama real & tangible

personal property -27,859,885

Book value of real & tangible personal

property in other states 85,125,584

Book value of merchandise held for sale 116,440,379

Cost of domestic capital stock owned 0

Total deductions 201,565,963

Total value of all shares of stock

remaining for assessment - 107,720,587

State assessment (not less than zero) 0

County assessments -5,571,977

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax 0

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax -135,560

Page 25 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1990

BellSouth Services, Inc.

(M: 12-31-91)

oreign Corporation: ax

Paid) 205,525

Domestic Corporation (As If)

Tapital Stock 500

Domestic Franchise Tax 50

Domestic Shares Tax:

Total value of all shares of stock 199, 464,259

Deductions:

Book value of real & tangible personal

property 120,346,979

Book value of Alabama real & tangible

personal property -19,490,253

Book value of real & tangible personal

property in other states 100,856,726

Book value of merchandise held for sale 128,430,648

Cost of domestic capital stock owned 3,519,888

Total deductions 232,807 262

Total value of all shares of stock

reinaining for assessment -33.343,003

State assessment (not less than zero) 0

County assessments -3,898,051

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax TET |

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax -205.475

Page 26 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1991

BellSouth Services, Inc.

Sar AS

oreign Corporation: ax

Paid) 206,333

Domestic Corporation (As If)

Tapital Stock 500

Domestic Franchise Tax 50

Domestic Shares Tax:

Total value of all shares of stock 179,420,666

Deductions:

Book value of real & tangible personal

property 116,095,920

Book value of Alabama real & tangible

personal property -27,283,729

Book value of real & tangible personal

property in other states 88,812,191

Book value of merchandise held for sale 89,704,570

Cost of domestic capital stock owned 11,762,377

Total deductions 190,279,138

Total value of all shares of stock

remaining for assessment -10,858 472

State assessment (not less than zero) 0

County assessments -5,456,746

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax 0

Total D eC ion T =

Domestic Tax over (under) Foreign Tax -206,283

Page 27 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1992

BellSouth Services, Inc.

(M: 12-31-91)

oreign Corporation: Franchise Tax

Paid) 2

Domestic Corporation (As If)

Capital Stock

D oF hise T

Domestic Shares Tax:

Total value of all shares of stock

Deductions:

Book value of real & tangible personal

property

Book value of Alabama real & tangible

personal property

Book value of real & tangible personal

property in other states

or

©

Book value of merchandise held for sale

Cost of domestic capital stock owned

Total deductions

Total value of all shares of stock

remaining for assessment

State assessment (not less than zero)

County assessments

Residue of total value of stock for

assessment (not < 0)

N/A Domestic Shares Tax

Total D °C ion T.

Domestic Tax over (under) Foreign Tax

| | —) (— i — nn — ee | — ee °

Page 28 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1986

BellSouth Financial Services

eee

oreign Corporation: ise Tax

Paid) 25

Domestic Corporation (As If)

Capital Stock 1,000

Domestic Franchise Tax eC US

Domestic Shares Tax:

Total value of all shares of stock -299.000

Deductions:

Book value of real & tangible personal

property 2,000

Book value of Alabama real & tangible

personal property 0

Book value of real & tangible personal

property in other states 2,000

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 2,000

Total value of all shares of stock

remaining for assessment -301.000

State assessment (not less than zero) 0

County assessments 0

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax ee a

Total D iC on T. =

Domestic Tax over (under) Foreign Tax 25

Page 29 of 88

Financial Data and Calculations Financial Data and Calculations

used in "As If Domestic” Analysis used in "As If Domestic” An“?- sis

prepared for counsel in anticipation prepared for counsel in anti .1tion

of South Central Bell case. of South Central Bell case.

1987 1988

BellSouth Financial Services BellSouth Financial Services

Corporation Corporation

Forsigs Useporation Franchise Tax Us Foreign Corporation Frenchine Ter

Domestic Corporation (As If) Domestic Co ]

rporation (As If)

Capital Stock 1,000 Capital Stock 1,000

Domestic Franchise Tax dae Domestic Franchise Tax peaeN |

Domestic S‘aares Tax: Domestic Shares Tax:

Total value of all shares of stock 613,000 Total value of all shares of stock -139,000

Deductions: Deductions:

Book value of real & tangible personal Book value of real & tangible personal

property 160.000 property 688,000

Book value of Alabama real & tangible Book value of Alabama real & tangible

personal property 0 rsonal rt 0

Book value of real & tangible personal mse 25 tt & tangible personal

property in other states 160.000 property in other states 688,000

Book value of merchandise held for sale 0 Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0 Cost of domestic capital stock owned 0

Total deductions 160,000 T uctio

Total value of all shares of stock fend se oe of all shares of stock =

remaining for assessment -973,000 remaining for assessment -827,000

State assessment (not less than zero) 0 State assessment (not less than zero) 0

County assessments 0

Residue of total value of stock for ee ee rear par l of stock for -

assessment (not < 0) | assessment (not < 0) 0

N/A Domestic Shares Tax 0 N/A Domestic Shares Tax 0

Total Domestic Corporation Tax 50 Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax 25 Domestic Tax over (under) Foreign Tax 25

Page 30 of 88 Page 31 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel ir anticipation

of South Central Bell case.

1989

BellSouth Financial Services

a

oreign Corporation: Franc ax

Paid) 130,334

Domestic Corporation (As If)

Capital Stock 1,000

D ti F } . T. Pena: amen

Domestic Shares Tax:

Total value of all shares of stock 4,803,000

Deductions:

Book value of real & tangible personal

property 4,947,000

Book value of Alabama real & tangible

personal property -664,382

Book value of real & tangible personal

property in other states 4,282,618

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 4.282.618

Total value of all shares of stock

remaining for assessment 520,382

State assessment (not less than zero) 104,07

County assessments -132,87

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax 0

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax -130.284

Page 32 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

BellSouth Financial Services

1990

Corporation

Foreign Conor Franchise Tax (As

Paid)

Domestic Corporation (As If)

S

16,

Capital Stock

D ‘c Franchise T

Domestic Shares Tax:

Total value of all shares of stock

Deductions:

Book value of real & tangible personal

property

Book value of Alabama real & tangible

personal

Book value of real & tangible personal

property

Book value of merchandise held for sale

Cost of domestic capital stock owned

property

in other states

Total deductions

Total value of all shares of stock

remaining for assessment

State assessment (not less than zero)

County assessments

Residue

of total value of stock for

assessment (not < 0)

N/A Domestic Shares Tax

Total D iC on T

Domestic Tax over (under) Foreign Tax

Page 33 of 88

|

7,904,000

5,051,000

-676,329

4,374,671

oOo ©

4,374,671

3,529,329

705,866

-135,266

570,600

39,657

39,707

22.799

Financial Data and Caiculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1991

BellSouth Financial Services

Corporation

Foreign Corporation: Franchise Tax (As

Paid) 28.539

Domestic Corporation (As If)

Capital Stock 500

D . F } . T. ee ee ae

Domestic Shares Tax:

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

Total value of all shares of stock 10,489,000

Deductions:

Book value of real & tangible personal

property 436,000

Book value of Alabama real & tangible

personal property -60,386

Book value of real & tangible personal

property in other states 375,614

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 375,614

Total value of all shares of stock

remaining for assessment 10,113,386

State assessment (not less than zero) 2,022,677

County assessments -12,077

Residue of total value of stock for

assessment (not < 0) 2,010,600

N/A Domestic Shares Tax 139,737

Total Domestic Corporation Tax 139,787

Domestic Tax over (under) Foreign Tax 111,248

Page 34 of 88

of South Central Bell case.

1992

BellSouth Financial Services

Corporation

Paid) 17,172

Domestic Corporation (As If)

Capital Stock 500

D . Fr. } . T PARES Sims

Domestic Shares Tax:

Total value of all shares of stock 11,492,000

Deductions:

Book value of real & tangible personal

property 325,000

Book value of Alabama real & tangible

personal property -41,919

Book value of real & tangible personal

property in other states 283.081

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 283.081

Total value of all shares of stock

remaining for assessment 11,208,919

State assessment (not less than zero) 2,241,784

County assessments -8,384

Residue of total value of stock for

assessment (not < 0) 2,233,400

N/A Domestic Shares Tax 155,221

Total Domestic Corporation Tax 155,271

Domestic Tax over (under) Foreign Tax 138,099

Page 35 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1986

BellSouth Advertising & Publishing

Sb

Foreign Corporation: Franchise Tax

Paid) 60,038

Domestic Corporation (As If)

Capital Stock 182,584,000

Domestic Franchise Tax 1,825,840

Domestic Shares Tax:

Total value of all shares of stock 182,907,000

Deductions:

Book value of real & tangible personal

property 10,189,000

Book value of Alabama real & tangible

personal property -1,227,114

Book value of real & tangible personal

property in other states 8,961,886

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 8,961,886

Total value of all shares of stock

remaining for assessment 173.945.114

County assessments

Residue of total value of stock for

oS

State assessment (not less than zero) 34,789,023

245,423

34

assessment (not < 0) 543.600

. noe

N/A Domestic Shares Tax 2,400,780

e ~ ————_—_K——E

Total Domestic Corporation Tax eee 8s226,620

Domestic Tax over (under) Foreign Tax 4,166,582

eae

Page 36 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1987

BellSouth Advertising & Publishing

Corporation

Foreign Corporaton: Franchise Tax Cis

Paid) 59.922

Domestic Corporation (As If)

Capital Stock ~~— 500

Domestic Franchise Tax 50

Domestic Shares Tax:

Total value of all shares of stock 181,263,587

Deductions:

Book value of real & tangible personal

property 9,553,000

Book value of Alabama real & tangible

personal property -786,038

Book value of real & tangible personal

property in other states 8,766,962

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 8,766,962

Total value of all shares of stock

remaining for assessment 172,496,625

State assessment (not less than zero) 34,499,325

County assessments -157,208

Residue of total value of stock for

assessment (not < 0) 34,342.117

N/A Domestic Shares Tax 2,386,777

Total Domestic Corporation Tax 2, 386,827

Domestic Tax over (under) Foreign Tax 2.326.905

Page 37 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1988

BellSouth Advertising & Publishing

Sa

oreign Corporation: Franc ax

Paid) 55,586

Domestic Corporation (As If)

Tapital Stock 500

D —— a

Domestic Shares Tax:

Total value of all shares of stock 181,265,000

Deductions:

Book value of real & tangible personal

property 8,934,000

Book value of Alabama rea! & tangible

personal property - 1,084,247

Book value of real & tangible personal

property in other states 7,849,753

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 7,849,753

Total value of all shares of stock

remaining for assessment 173.415.247

State assessment (not less than zero) 34,683,049

County assessments -216,849

Residue of total value of stock for

assessment (not < 0) 34-466 200

N/A Domestic Shares Tax 2,395,401

Total Domestic Corporation Tax

oe

Domestic Tax over (under) Foreign Tax 2.339.865

oe

Page 38 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1989

BellSouth Advertising & Publishing

eet

oreign Corporation: ax

Paid) 56,659

Domestic Corporation (As If)

Capital Stock 500

D - Franchise T emene |

Domestic Shares Tax:

Total value of all shares of stock 211,263,587

Deductions:

Book value of real & tangible personal

property 11,586,000

Book value of Alabama real & tangible

personal property -606,940

Book value of real & tangible personal

property in other states 10,979,060

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 10,979,060

Total value of all shares of stock

remaining for assessment 200,284,527

State assessment (not less than zero) 40,056,905

County assessments -121,388

Residue of total value of stock for

assessment (not < 0) 39,935,517

N/A Domestic Shares Tax 2,775,518

Total Domestic Corporation Tax ee 2s 15,568

Domestic Tax over (under) Foreign Tax 2.718.909

Page 39 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1990

BellSouth Advertising & Publishing

Corporation

Foreign Useporstion: Franck Tax Ue

Paid) 71,861

Domestic Corporation (As If)

Capital Stock 500

D = Pranchiee T a

Domestic Shares Tax:

Total value of all shares of stock 266,568,534

Deductions:

Book value of real & tangible personal

property 11,709,000

Book value of Alabama real & tangible

personal property -445,794

Book value of real & tangible personal

property in other states 11,263,206

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 11,263,206

Total value of all shares of stock

remaining for assessment 255.305 328

State assessment (not less than zero) 51,061,066

County assessments -89,159

Residue of total value of stock for

assessment (not < 0) 50.971,907

N/A Domestic Shares Tax 3,542,548

Total Domestic Corporation Tax 542,598

Domestic Tax over (under) Foreign Tax 3,470,737

Page 40 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1991

BellSouth Advertising & Publishing

ae

oreign Corporation: ax (As

Paid) 75,421

Domestic Corporation (As If)

Tapital Stock 500

D i Franchise T, 7

Domestic Shares Tax:

Total value of all shares of stock 313,851,000

Deductions:

Book value of real & tangible personal

property 15,768,000

Book value of Alabama real & tangible

personal property -1,432,586

Book value of real & tangible personal

property in other states 14,335,414

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 14,335,414

Total value of all shares of stock

remaining for assessment 299,515,586

State assessment (not less than zero) 59,903,117

County assessments -286,517

Residue of total value of stock for

assessment (not < 0) 59.616,600

N/A Domestic Shares Tax 4,143,354

Total Domestic Corporation Tax 4.143.404

Domestic Tax over (under) Foreign Tax 4.067.983

Page 41 of 88

Financial Data and Caiculations Financial Data and Calculations

ane ero pe » used in "As If Domestic” Analysis

Phan ee — yay sey for ceny s in anticipation

7) Centra case.

1992 1986

BellSouth Advertising & Publishing BellSouth R iad:

a ration Foreign Corporation. ae Tax (As

oreign Corporation: ax Paid)

Paid) 65,829

: ;

Domestic Corporation (As If) ——S Domestic Corporation (As If)

Tapital Stock 500 - ; : meen |

Domestic Franchise Tax 50 an

: anne Domestic Shares Tax:

Domestic Shares Tax:

Total value of all shares of stock 342,978,437 ar 1 ~o cnan agama

Deductions: , '

Book value of real & tangible personal . me of real & tangible personal

property 15,085,000 '

Book value of Alabama real & tangible ea real & tangible

personal property -773,064 a

Book value of real & tangible personal Book a a ae le personal P

property in other states 14,311,936 papary

Book value of merchandise held for sale 0 oe agen p — ™

Cost of domestic capital stock owned 0 Total deducti _ 7

Total deductions 14,511,996 Total value of all shares of stock

Total value of all shares of stock sumataina ton om °

ST ena ee State assessment (not less than zero) 0

State assessment (not less than zero) 65,733,300 County ts 0

County assessments -154,613 Residue of total value of stock fer

Residue of total value of stock for nt (not <0) °

assessment (not < 0) 65,578,687 ‘ eee

, SS = N/A Domestic Shares Tax 0

N/A Domestic Shares Tax 4,557,719 Total D 7; on T eee |

Total Domestic Corporation Tax 4,557,769 ee

Domestic Tax over (under) Foreign Tax 4.491.940 etic Tax over (under) Foreign Tax a |

Page 42 of 88 Page 43 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1987

BellSouth Resources, Inc.

Paid)

Domestic Corporation (As If)

Capital Stock

D -- Franchise T,

Domestic Shares Tax:

Total value of all shares of stock

Deductions:

Book value of real & tangible personal

property

Book value of Alabama real & tangible

personal property

Book value of real & tangible personal

property in other states

Book value of merchandise held for sale

Cost of domestic capital stock owned

Total deductions

Total value of all shares of stock

remaining for assessment

State assessment (not less than zero)

County assessments

Residue of total value of stock for

assessment (not < 0)

N/A Domestic Shares Tax

Total D T on T

Domestic Tax over (under) Foreign Tax

ill o | o =

Page 44 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

BellSouth Resources, Inc.

Foreign Corporation: Pomche Tax (As

Paid)

Domestic Corporation (As If)

Capital Stock

Domestic Franchise Tax

Domestic Shares Tax:

Total value of all shares of stock

Deductions:

Book value of real & tangible personal

property

Book value of Alabama real & tangible

personal property

Book value of real & tangible personal

property in other states

1988

Book value of merchandise held for sale

Cost of domestic capital stock owned

Total deductions

Total value of all shares of stock

remaining for assessment

State assessment (not less than zero)

County assessments

Residue of total value of stock for

assessment (not < 0)

N/A Domestic Shares Tax

Total D eC. ration T.

Domestic Tax over (under) Foreign Tax

ill —) | ° —

Page 45 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1989

— entree en

oreign Corporation: Franchise Tax

Paid) 25

Domestic Corporation (As If)

Capital Stock 500

Domestic Franchise Tax 50

Domestic Shares Tax:

Total value of all shares of stock 500

Deductions:

Book value of real & tangible personal

property 0

Book value of Alabama real & tangible

personal property 0

Book value of real & tangible personal :

property in other states 0

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 0

Total value of all shares of stock

remaining for assessment 500

State assessment (not less than zero) 100

County assessments 0

Residue of total value of stock for

assessment (not < 0) 100

N/A Domestic Shares Tax 7

Total Domestic Corporation Tax 57

Domestic Tax over (under) Foreign Tax 32

Page 46 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1990

a

oreign Corporation: Franchise Tax

Paid) 4.576

Domestic Corporation (As If)

Capital Stock 500

Domestic Franchise Tax 50

Domestic Shares Tax:

Total value of all shares of stock 4,434,000

Deductions:

Book value of real & tangible personal

property 369,000

Book value of Alabama real & tangible

personal property -193,408

Book value of real & tangible personal

property in other states 175,592

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 175,592

Total value of all shares of stock

remaining for assessment 4 258,408

State assessment (not less than zero) 851,682

County assessments -38,682

Residue of total value of stock for

assessment (not < 0) 813,000

N/A Domestic Shares Tax 56,504

Total Domestic Corporation Tax 56,554

Domestic Tax over (under) Foreign Tax 51,978

Page 47 of 88

Financial Data and Calculations Financial Data and Calculations

used in "As If Domestic” Analysis : z

prepared for counsel in anticipation used in "As If Domestic” Analysis

of South Central Bell case. prepared for counsel in anticipation

of South Central Bell case.

me 1992

BellSouth Resources, Inc.

Foreign Corporation: a ax BellSouth Resou Inc.

Paid) 2 720 Foreign Corporation. Pane Tax (As

;, , Paid) 287

Ca — ——— eal nnn EL 500 Domestic Corporation (As If)

: Domestic Franchise Tax 50 Capital Stock 500

;

Domestic Shares Tax: Pirie. ox amare — SOT |

ace ee cei Total value of all shares of stock -15,000

Deductions:

pa gy er ee 447.000 Book value of real & tangible personal

1 | property 7,000

ee veal & tangible 199.872 Book value of Alabama real & tangible

Book value of real & tangible personal as yg stip need ieee area 0

property in other states 247,128 Vere SF oe e pe

property in other states 7,000

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0 Book value of merchandise held for sale 0

Total deductions 247.128 Cost of domestic capital stock owned 0

Total value of all shares of stock Total deductions 7,000

fey Total value of all shares of stock

remaining for assessment 2,370,872 bir coy eres ve

State assessment (not less than zero) 474,174 mabiities -22.

County assessments 39.974 State assessment (not less than zero) 0

Residue of total value of stock for County assessments 0

assessment (not < 0) 434.200 Residue of total value of stock for

N/A Domestic Shares Tax | assessment (not < 0) 0

Ti ; See N/A Domestic Shares Tax 0

Total Domestic Corporation Tax ;

as Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax 27,507 hicciiasnie: Can ster Giiliak ieaten tun i

Page 48 of 88 Page 49 of 88

Financial Data and Calculations Financial Data and Calculations

used in "As If Domestic” Analysis used in "As If Domestic” Analysis

prepared for counsel in anticipation ared for counsel in anticipation

of South Central Bell case. pe sect Central Bell case

BellSouth Products, Inc -_ nae

e ,

Foreign Corporation: Franchise Tax (As ot ape a

Paid) me Paid) :

Domestic Corporation (As If) ——<—————

5 OTHE t ration (As I,

so ee - Domestic Corporation (As If)

Domestic Franchise Tax Rerceeane Domestic Franchise Tax era

Domestic Shares Tax:

Total value of all shares of stock raat por tga 5 coll of stock

Deductions: Deductions:

Book value of real & tangible personal Book value of real & tangible personal

property

Book value of Alabama real & tangible oe nll of Alabama real & tangible

personal property :

Book value of real & tangible personal eae & tangible personal

property in other states 0 property in other states 0

Book value of merchandise held for sale Book value of merchandise held for sale

Cost of domestic capital stock owned Cost of domestic capital stock owned

Total deductions 0 Total deductions 0

Total value of all shares of stock Total value of all shares of stock

remaining for assessment 0 remaining for assessment 0

State assessment (not less than zero) 0 State assessment (not less than zero) 0

County assessments 0

Residue of total value of stock for ee oo, of stock for °

assessment (not < 0) 0 assessment (not < 0) 0

. a = eee

N/A Domestic Shares Tax 0 N/A Domestic Shares Tax 0

Total Domestic Corporation Tax ES | Total Domestic Corporation Tax seat al

Domestic Tax over (under) Foreign Tax 0 Domestic Tax over (under) Foreign Tax 0

Page 50 of 88 Page 51 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

BellSouth Produ Inc.

Foreign Corporation. + Tax (As

Paid)

Domestic Corporation (As If)

Capital Stock

D oF hise T;

Domestic Shares Tax:

Total value of all shares of stock

Deductions:

Book value of real & tangible personal

property

Book value of Alabama real & tangible

personal property

Book value of real & tangible personal

property in other states

1988

Book value of merchandise held for sale

Cost of domestic capital stock owned

Total deductions

Total value of all shares of stock

remaining for assessment

State assessment (not less than zero)

County assessments

Residue of total value of stock for

assessment (not < 0)

N/A Domestic Shares Tax

Total D <C on T

Domestic Tax over (under) Foreign Tax

ill ° | ° °

Page 52 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

BellSouth Produ Inc.

—————eSE

Paid)

Domestic Corporation (As If)

Capital Stock

D ic Franchise T.

Domestic Shares Tax:

Total value of all shares of stock

Deductions:

Book value of real & tangible personal

property

Book value of Alabama real & tangible

personal property

Book value of real & tangible personal

property in other states

1989

Book value of merchandise held for sale

Cost of domestic capital stock owned

Total deductions

Total value of all shares of stock

remaining for assessment

State assessment (not less than zero)

County assessments

Residue of total value of stock for

assessment (not < 0)

N/A Domestic Shares Tax

Total D iC ion T

Domestic Tax over (under) Foreign Tax

Page 53 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1990

BellSouth Produ Inc.

Foreign Corporation. Sa Tax (As

Paid)

Domestic Corporation (As If)

Capital Stock

D a hise T

Domestic Shares Tax:

Total value of all shares of stock

Deductions:

Book value of real & tangible personal

property

Book value of Alabama real & tangible

personal property

Book value of real & tangible personal

property in other states

Book value of merchandise held for sale

Cost of domestic capital stock owned

Total deductions

Total value of all shares of stock

remaining for assessment

State assessment (not less than zero)

County assessments

Residue of total value of stock for

assessment (not < 0)

N/A Domestic Shares Tax

Total D <C on T

Domestic Tax over (under) Foreign Tax

Page 54 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

BellSouth Produ Inc.

oreign : ax

Paid)

Domestic Corporation (As If)

api

D cB hise T

Domestic Shares Tax:

Total value of all shares of stock

Deductions:

Book value of real & tangible personal

property

Book value of Alabama real & tangible

personal property

Book value of real & tangible personal

property in other states

Book value of merchandise held for sale

Cost of domestic capital stock owned

Total deductions

Total value of all shares of stock

remaining for assessment

State assessment (not less than zero)

County assessments

Residue of total value of stock for

assessment (not < 0)

N/A Domestic Shares Tax

Total D iC ion T.

Domestic Tax over (under) Foreign Tax

Page 55 of 88

o

0

0

0

a)

0

Financial Data and Calculations Financial Data and Calculations

used in "As If Domestic” Analysis used in "As If Domestic” Analysis

prepared for counsel in anticipation prepared for counsel in anticipation

of South Central Bell case. of South Central Bell case.

1992 1986

BellSouth Produ Inc. Alabama Cellular Se Inc.

Foretga Corporations Franchise Tox Us Forsign Conporation Frases Tate

Paid) ———— | Paid) een 205. 205

Domestic Corporation (As If) Domestic Corporation (As If)

Capital Stock 500 Tapital Stock oe

Domestic Franchise Tax a | Domestic Franchise Tax 50

Domestic Shares Tax:

Total value of all shares of stock “806,987 Tour “cece » ol of stock 4,201,816

Deductions: Deductions: |

Book value of real & tangible personal Book value of real & tangible personal

property °

Book value of Alabama real & tangible is te ge of Alabama real & tangible TT

personal property 0 rsonal rt -4,486,696

Book value of real & tangible persona! a8 nett sa & tangible personal posi

property in other states 0 property in other states 0

Book value of merchandise held for sale 2,523,042 ,

Cost of domestic capital stock owned 0 ae Pn babrepas 5° peat / ~

Total deductions 2,523,042 Total deductions 0

Total value of all shares of stock Total value of all shares of stock

remaining for assessment 23: 330,029 specie:

aining for assessment 4,201,816

State assessment (not less than zero) 0 State assessment (not less than zero) 840,363

County assessments 0 County assessments -897.339

Residue of total value of stock for actin Atel wiles af ttedh fe

assessment (not < 0) = | assessment (not < 0) vest |

N/A Domestic Shares Tax oe | N/A Domestic Shares Tax 0

Domestic Tax over (under) Foreign Tax 25 ;

— Domestic Tax over (under) Foreign Tax een 15,155

Page 56 of 88 Page 57 of 88

Financial Data and Calculations Financial Data and Calculations

used in "As If Domestic” Analysis

used in "As If Domestic” Analysis

prepared for counsel in anticipation cad ae ae in dastdieaiten

of South Central Bell case. of South Central Bell case.

1987 1988

Alabama Cellular Services, Inc.

Toe Conon Fae Alabama Cellular Services, Inc.

ee ee Foreign Corporation. Franchise To (As

Paid) 13,819 Paid) 43,602

Domestic Corporation (As If) Domestic Corporation (As If) ,

Tapital Stock Tapital Stock

‘ “ " aaa

Domestic Sh T . ; =

mestic Shares Tax:

Total value of all shares of stock 4,552,064 ae sedate 9 a, of stock 10.894.149

Deductions: Deductions: ents

Book value of real & tangible personal : Book value of real & tangible personal

property . 4,437,203 property 9 055,894

Bock vee of Alsbams seat © tangitte Book value of Alabama real & tangible

personal property -4,437 203 personal property -9,055,894

Book value of real & tangible personal Book value of real & tangible personal |

property in other states 0 property in other states 0

Book value of merchandise held for sale 0 Book value of merchandise held for sale 0

Cost of domestic capital stock owned : Cost of domestic capital stock owned 0

Total deductions 0 Total deducti 0

Total value of all shares of stock Total value of all shares of stock

remaining for assessmeat pe Se remaining for assessment 10,894,149

State assessment (not less than zero) 910,413 State assessment (not less than zero) 7 178,830

ol assessments £87,441 County assessments -1,811,179

sidue of total value of stock for Residue of total value of stock for

assessment (not < 0) 22.972 assessment (not < 0) 367,651

N/A ! | 1,597 N/A Domestic Shares Tax 25,552

fatal Domestic Corporation Tax ee Ud Total Domestic Corporation Tax 25,602

a ee

Domestic Tax over (under) Foreign Tax -12,172 Domestic Tax over (under) Foreign Tax 18,000

——————— —

Page 58 of 88 Page 59 of 88

Financial Data and Calculations Financial Data and Calculations

used in "As If Domestic” Analysis — used in "As If Domestic” Analysis

prepared for counsel in anticipation prepared for counsel in anticipation

of South Central Bell case. of South Central Bell case.

1989 1990

Alabama Cellular Services: Inc. Alabama Cellular Services. Inc.

oreign Corporation: Franc ax U Foreign Corporation: Franchise To (As

Paid) 40,402 Paid) 45.069

Domestic Corporation (As If) Domestic Co

rporation (As If)

Domestic Franchise Tax 50 Domestic Franchise Tax 50

Domestic Shares Tax: Domestic Sharee Tax: ee

Total value of all shares of stock 13,389,444 Total value of all shares of stock 15,014,123

Deductions: Deductions:

Book value of real & tangible personal Book value of real & tangible personal

Book value of Alabama real & tangible Book value of Alabama real & tangible

personal property -10,432,979 personal property -12,504,179

Book value of real & tangible personal Book value of real & tangible personal

property in other states 0 property in other states 0

Book value of merchandise held for sale 0 Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0 Cost of domestic capital stock owned 0

Total deductions 0 Total deducti 0

Total value of all shares of stock Teta) value . ail shares of stock

remaining for assessment 13,389,444 remaining for assessment 15,014,123

State assessment (not less than zero) 2,677,889 State assessment (not less than zero) 3,002,825

County assessments -2,086,596 Co ts 2

Residue of total \ alue of stock for err ae se te of stock for aeee

assessment (not < 0) 591,293 assessment (not < 0) 501,989

‘ ——S eee

N/A Domestic Shares Tax 41,095 N/A Domestic Shares Tax 34,888

Total Domestic Corporation Tax 41,145 Total Domestic Corporation Tax pean

od

Domestic Tax over (under) Foreign Tax 743 Domestic Tax over (under) Foreign Tax -10,131

Page 60 of 88 Page 61 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1991

oreign Corporation: Franchise lax (

Paid) 64,880

Domestic Corporation (As If)

Capital Stock : 0

Domestic Franchise Tax - 50

Domestic Shares Tax:

Total value of all shares of stock 21,578,000

Deductions:

Book value of real & tangible personal

property 13,973,000

Book value of Alabama real & tangible

personal property -13,973,000

Book value of real & tangible personal

property in other states 0

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 0

Total value of all shares of stock

remaining for assessment 21,578,000

State assessment (not less than zero) 4,315,600

County assessments -2,794,600

Residue of total value of stock for

assessment (not < 0) 1,521,000

N/A Domestic Shares Tax 105,710

Total Domestic Corporation Tax 105,760

Domestic Tax over (under) Foreign Tax 40,880

Page 62 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1992

Alabama Cellular Services, Inc.

Foreign Corporation: Franchise Tax Gs

Paid) 81,291

Domestic Corporation (As If)

Capital Stock 0

Domestic Franchise Tax 50

Domestic Shares Tax:

Total value of all shares of stock 27,097,000

Deductions:

Book value of real & tangible personal

property 23,080,000

Book value of Alabama real & tangible

personal property -23,080,000

Book value of real & tangible personal

property in other states 0

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 0

Total value of all shares of stock

remaining for assessment 27,097,000

State assessment (not less than zero) 5,419,400

County assessments -4,616,000

Residue of total value of stock for

assessment (not < 0) 803,400

N/A Domestic Shares Tax 55,836

Total Domestic Corporation Tax 55,886

Domestic Tax over (under) Foreign Tax -25,405

Page 63 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1986

a Corporatio. -

oreign Corporation: Franchise Tax (As

Paid) 10,939

Domestic Corporation (As If)

Capital Stock 11,367,000

Domestic Franchise Tax 113,670

Domestic Shares Tax:

Total value of all shares of stock 11,366,000

Deductions:

Book value of real & tangible personal

property 10,490,000

Book value of Alabama real & tangible

personal property -2,819.961

Book value of real & tangible personal

property in other states 7,670,039

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 7,670,039

Total value of all shares of stock

remaining for assessment 3,695,961

State assessment (not less than zero) 739,192

County assessments -563,992

Residue of total value of stock for

assessment (not < 0) 175,200

N/A Domestic Shares Tax 12,176

Total Domestic Corporation Tax 125,846

Domestic Tax over (under) Foreign Tax 114,907

Page 64 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1987

SEE

oreign Corporation: ax

Paid) 6,776

Domestic Corporation (As If) ea

Capital Stock 1,000

Domestic Franchise Tax 50

Domestic Shares Tax:

Total value of all shares of stock 11,360,000

Deductions:

Book value of real & tangible personal

property 8,947,000

Book value of Alabama rea! & tangible

personal property -2.764, 195

Book value of real & tangible personal

property in other states 6, 182,805

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 6, 182,805

Total value of all shares of stock

remaining for assessment 5,177,195

State assessment (not less than zero) 1,035,439

County assessments -552,839

Residue of total value of stock for

assessment (not < 0) 482.600

N/A Domestic Shares Tax 33,541

Total Domestic Corporation Tax 33,591

Domestic Tax over (under) Foreign Tax 26.815

Page 65 of 88

Financial Data and Calculations

used in “As If Domesiic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1988

oreign Corporation: Franc ax

Paid) 5,840

Domestic Corporation (As If)

Capital Stock 1,000

D cK hise T a

Domestic Shares Tax:

Total value of all shares of stock 11,368,000

Deductions:

Book value of real & tangible personal

property 11,780,000

Book value of Alabama real & tangible

personal property -2.695,756

Book value of real & tangible personal

property in other states 9,084,244

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 9,084,244

Total value of all shares of stock

remaining for assessment 2,283 756

State assessment (not less than zero) 456,751

County assessments -539,151

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax PS ET |

T D ‘ . . T et

Domestic Tax over (under) Foreign Tax -5.790

Page 66 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1989

Se

oreign : ax

Paid) 7,769

Domestic Corporation (As If)

apl 1,000

D :- Pranchiee T come |

Domestic Shares Tax:

Total value of all shares of stock 11,355,000

Deductions:

Book value of real & tangible personal

property 18,249,600

Book value of Alabama real & tangible

personal property -2,356,241

Book value of real & tangible personal

property in other states 15,892,759

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 15,892,759

Total value of all shares of stock

remaining for assessment 4.537.759

State assessment (not less than zero) 0

County assessments 471,248

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax 0

r | D . 5 ‘ 7 WME |

Domestic Tax over (under) Foreign Tax -7,.719

Page 67 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1990

Sunlink Corporation

Foreign Corporation. eee Tax (As

Paid) 37,952

Domestic Corporation (As If)

Capital Stock 500

Domestic Franchise Tax 50

Domestic Shares Tax:

Total value of all shares of stock 24,751,000

Deductions:

Book value of real & tangible personal

property 24,069,000

Book value of Alabama real & tangible

personal property -7,590,075

Book value of real & tangible personal

property in other states 16,478,925

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 16,478,925

Total value of all shares of stock

remaining for assessment 8.272.075

State assessment (not less than zero) 1,654,415

County assessments -1,518,015

Residue of total value of stock for

assessment (not < 0) 136.400

N/A Domestic Shares Tax 9,480

Total Domestic Corporation Tax 9.530

Domestic Tax over (under) Foreign Tax -28 422

Page 68 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1991

Foreign Corporation Feoehiae Tax Oe

oreign Corporation: ax

Paid) 24,108

Domestic Corporation (As If)

Tapital Stock ‘ 500

D ‘- Franchise Tax - SEER

Domestic Shares Tax:

Total value of all shares of stock 24,739,593

Deductions:

Book value of real & tangible personal

property 30,581,000

Book value of Alabama real & tangible

personal property -7,498, 806

Book value of real & tangible personal

property in other states 23,082,194

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 23,082,194

Total value of all shares of stock

remaining for assessment 1,657,399

State assessment (not less than zero) 331,480

County assessments -1,499,761

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax MCI |

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax -24.058

Page 69 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1992

oreign Corporation: Fran ax

Paid) 15,199

Domestic Corporation (As If)

Capital Stock 500

D cK hise T. a

Domestic Shares Tax:

Total value of all shares of stock 25,791,479

Deductions:

Book value of real & tangible personal

property 29,731,000

Book value of Alabama real & tangible

personal property -7,467,331

Book value of real & tangible personal

property in other states 22,263,669

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 22,263,669

Total value of all shares of stock

remaining for assessment 3,527,810

State assessment (not less than zero) 705,562

County assessments -1,493, 466

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax NTS |

Total Domestic Corporation Tax 50

Domestic Tax over (under) Foreign Tax -15.149

Page 70 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1986

TechSouth, Inc.

Foreign Corporation. Franchise Tax (As

Paid) 4,242

Domestic Corporation (As If)

Capital Stock 102,500

Domestic Franchise Tax 1,025

Domestic Shares Tax:

Total value of all shares of stock 2,687,104

Deductions:

Book value of real & tangible personal

property 1,056,754

Book value of Alabama real & tangible

personal property 434,238

Book value of real & tangible personal

property in other states 622,516

Book value of merchandise held for sale 21,220

Cost of domestic capital stock owned 0

Total deductions 643,736

Total value of all shares of stock

remaining for assessment 2.043.368

State assessment (not less than zero) 408,674

County assessments -86, 848

Residue of total value of stock for

assessment (not < 0) 321,826

N/A Domestic Shares Tax 22,367

Total Domestic Corporation Tax 23.392

Domestic Tax over (under) Foreign Tax 19.150

Page 71 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1987

TechSouth, Inc.

Foreign Corporation: Franchise Tax (is

Paid) 4.756

Domestic Corporation (As If)

Tapital Stock 101,500

Domestic Franchise Tax 1,015

Domestic Shares Tax:

Total value of all shares of stock 2,838,978

Deductions:

Book value of real & tangible personal

property 1,672,700

Book value of Alabama real & tangible

personal property -594,272

Book value of real & tangible personal

property in other states 1,078,428

Book value of merchandise held for sale 37,545

Cost of domestic capital stock owned 0

Total deductions 1,115,973

Total value of all shares of stock

remaining for assessment 1,723,005

State assessment (not less than zero) 344,601

County assessments -118,854

Residue of total value of stock for

assessment (not < 0) 225,747

N/A Domestic Shares Tax 15,689

Total Domestic Corporation Tax 16,704

Domestic Tax over (under) Foreign Tax 11,948

Page 72 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1988

TechSouth, Inc.

Foreign Corporation: Franchise Tax (As

Paid) 4,835

Domestic Corporation (As If)

Capital Stock 101,500

Domestic Franchise Tax 1,015

Domestic Shares Tax:

Total value of all shares of stock 2,339,561

Deductions:

Book value of real & tangible personal

property 2,383,599

Book value of Alabama real & tangible

personal property ___ -672,193

Book value of real & tangible personal

property in other states 1,711,406

Book value of merchandise held for sale 200,285

Cost of domestic capital stock owned 0

Total deductions 1,911,691

Total value of all shares of stock

remaining for assessment 427,870

State assessment (not less than zero) 85,574

County assessments -134,439

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax eae

Total Domestic Corporation Tax 1,015

Domestic Tax over (under) Foreign Tax -8,820

Page 73 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1989

TechSouth, Inc.

Foreign Corporation: Franchise Tax (As

Paid) 2,753

Domestic Corporation (As If)

Capital Stock 101,500

Domestic Franchise Tax 1,015

Domestic Shares Tax:

Total value of all shares of stock 3,482,303

Deductions:

Book value of real & tangible personal

property 2,818,688

Book value of Alabama real & tangible

personal property -1,101,974

Book value of real & tangible personal

property in other states 1,716,714

Book value of merchandise held for sale 404,854

Cost of domestic capital stock owned 0

Total deductions 2,121,568

Total value of all shares of stock

remaining for assessment 1,360,735

State assessment (not less than zero) 272,147

County assessments -220,395

Residue of total value of stock for

assessment (not < 0) 51,752

N/A Domestic Shares Tax 3,597

Total Domestic Corporation Tax 4,612

Domestic Tax over (under) Foreign Tax 1,859

Page 74 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1990

TechSouth, Inc.

Foreign Corporation: Franchise Tax (As

Paid) 3.610

Domestic Corporation (As If)

Capital Stock 98,000

Domestic Franchise Tax 980

Domestic Shares Tax:

Total value of all shares of stock 2,867,000

Deductions:

Book value of real & tangible personal

property 2,835,000

Book value of Alabama real & tangible

personal property -1,108,485

Book value of real & tangible personal

property in other states 1,726,515

Book value of merchandise held for sale 133,000

Cost of domestic capital stock owned 0

Total deductions 1,859,515

Total value of all shares of stock

remaining for assessment 1,007,485

State assessment (not less than zero) 201,497

County assessments 221,697

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax et |

Total Domestic Corporation Tax 980

Domestic Tax over (under) Foreign Tax -2.630

Page 75 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

1991

TechSouth, Inc.

Foreign Corporation: Franchise Tax (As

Paid) 2,753

Domestic Corporation (As If)

‘Capital Stock 98,000

Domestic Franchise Tax 980

Domestic Shares Tax:

Total value of all shares of stock 1,401,000

Deductions:

Book value of real & tangible personal

property 2,471,000 -

Book value of Alabama real & tangible

personal property -840,243

Book value of real & tangible personal

property in other states 1,630,757

Book value of merchandise held for sale 78,000

Cost of domestic capital stock owned 0

Total deductions 1,708,757

Total value of all shares of stock

remaining for assessment 307,757

State assessment (not less than zero) 0

County assessments 168,049

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax PAO |

| | . , - mas:

Domestic Tax over (under) Foreign Tax -1,773

Page 76 of 88

remaining for assessment

State assessment (not less than zero)

County assessments

Residue of total value of stock for

assessment (not < 0)

N/A Domestic Shares Tax

Total D °C ion T

Domestic Tax over (under) Foreign Tax

Page 77 of 88

of South Central Bell case.

1992

TechSouth, Inc.

Foreign Corporation: Franchise Tax (is

Paid) 25

Domestic Corporation (As If)

Capital Stock 4.558

D ic Franchise T. sremmeucee |

Domestic Shares Tax:

Total value of all shares of stock -196,951

Deductions:

Book value of real & tangible personal

property 1,838,000

Book value of Alabama real & tangible

personal property - 1,072,468

Book value of real & tangible personal

property in other states 765,532

Book value of merchandise held for sale 21,000

Cost of domestic capital stock owned 0

Total deductions 786,532

Total value of all shares of stock

983,483

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1986

SEE aS EERIE

oreign Corporation: Franchise Tax

Paid) 555,951

Domestic Corporation (As If)

Capital Stock 229 220,760

Domestic Franchise Tax 2,292, 208

Domestic Shares Tax:

Total value of all shares of stock 2,178,687,840

Deductions:

Book value of real & tangible personal

property 3,939,514,364

Book value of Alabama real & tangible

personal property

Book value of real & tangible personal

property in other states 3,939,514,364

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 3,939,514,364

Total value of all shares of stock

remaining for assessment -1,760,826,524

State assessment (not less than zero) 0

County assessments 0

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax 0

Total Domestic Corporation Tax 2,292,208

es

Domestic Tax over (under) Foreign Tax 1,736,257

7 SSS

Page 78 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1987

CSX rtation, Inc.

oreign Corporation: ise Tax

Paid) 557.066

Domestic Corporation (As If)

Tapital Stock 217,220,760

—SS|~"~"S["ESlSl"™"[=

Domestic Franchise Tax 2.172.208

Domestic Shares Tax:

Total value of all shares of stock 2.265,314,567

Deductions:

Book value of real & tangible personal

property 4,126,104.417

Book value of Alabama real & tangible

personal property

Book value of real & tangible personal

property in other states 4, 126,104,417

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 4,126,104,417

Total value of all shares of stock

remaining for assessment - 1,860,789, 850

State assessment (not less than zero) 0

County assessments 0

Residue of total valu. of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax 0

Total Domestic Corporation Tax 2,172,208

Domestic Tax over (under) Foreign Tax 1.615.142

Page 79 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1988

CSX Transportation, Inc.

Foreign Corporation. Franchize Tax (As

Paid) 570,472

Domestic Corporation (As If) ——__

Capital Stock 245,220,760

. . _—<$———_—___________4

Domestic Franchise Tax 2,452,208

Domestic Shares Tax:

Total value of all shares of stock 4.091.698,803

Deductions:

Book value of real & tangible personal

property 7,337 ,924,567

Book value of Alabama real & tangible

personal property

Book value of real & tangible personal

property in other states 7,337 ,924,567

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 7,337,924 567

Total value of all shares of stock

remaining for assessment -3.246, 225.764

State assessment (not less than zero) 0

County assessments 0

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax

Total Domestic Corporation Tax 2.452.208

Domestic Tax over (under) Foreign Tax 1,881,736

Page 80 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1989

CSX rta Inc.

oreign ration: ax

Paid) 574,252

Domestic Corporation (As If)

Tapital Stock 184,553,960

Domestic Franchise Tax 1,845,540

Domestic Shares Tax:

Total value of all shares of stock 3,560,970,910

Deductions:

Book value of real & tangible personal

property 7,415,969,571

Book value of Alabama real & tangible

personal property 0

Book value of real & tangible personal

property in other states 7,415,969,571

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 7,415,969,571

Total value of all shares of stock

remaining for assessment -3,854,998.661

State assessment (not less than zero) 0

County assessments 0

Residue of total value of stuck for

assessment (not < 0) 0

N/A Domestic Shares Tax 0

Total Domestic Corporation Tax 1,845,540

Domestic Tax over (under) Foreign Tax 1.271.288

Page 81 of 88

Financial Data and Calculations

used in “As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1990

CSX Transportation, Inc.

Foreign Corporation: nies Tax (As

Paid) 573,792

Domestic Corporation (As If)

Capital Stock 181,220,760

Domestic Franchise Tax 1,812,208

Domestic Shares Tax:

Total value of all shares of stock

Deductions:

Book value of real & tangible personal

property

Book value of Alabama real & tangible

personal property

Book value of real & tangible personal

property in other states

Book value of merchandise held for sale

Cost of domestic capital stock owned

Total deductions

Total value of all shares of stock

remaining for assessment

State assessment (not less than zero)

County assessments

Residue of total value of stock for

assessment (not < 0)

N/A Domestic Shares Tax

Total D <C ion T,

Domestic Tax over (under) Foreign Tax

Page 82 of 88

3,720,564,633

7,657,131,790

0

7,657,131,790

0

0

7,657, 131,790

-3,936,567 157

0

0

0

1,812,208

(9 ers

8

1,238,416

——— es

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1991

CSX Tr rtation, Inc.

Foreign Comaration Foams Tax (As

Paid) | 571,327

Domestic Corporation (As If)

Tapital Stock | 181,220,760

Domestic Franchise Tax 812,208

Domestic Shares Tax:

Total value of all shares of stock 3,907,078.548

Deductions:

Book value of real & tangible personal

property 7,806,579.156

Book value of Alabama real & tangible

personal property 0

Book value of real & tangible personal

property in other states 7,806,579, 156

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 7,806,579, 156

Total value of all shares of stock

remaining for assessment -3,899,500,608

State assessment (not less than zero) 0

County assessments 0

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax eeemernea |

Total Domestic Corporation Tax 1,812,208

Domestic Tax over (under) Foreign Tax 1,240,881

Page 83 of 88

Financial Data and Calculations

used in "As If Domestic” Analysis

prepared for counsel in anticipation

of South Central Bell case.

1992

IGE SI LEU LAGE Sa

oreign Corporation: ax

Paid) 567,946

Domestic Corporation (As If)

Capital Stock 181,220,760

Domestic Franchise Tax 1,812,208

Domestic Shares Tax:

Total value of all shares of stock 3,493,482,716

Deductions:

Book value of real & tangible personal

property 8,001,201,780

Book value of Alabama real & tangible

personal property 0

Book value of real & tangible personal

property in other states 8,001,201,780

Book value of merchandise held for sale 0

Cost of domestic capital stock owned 0

Total deductions 8,001,201,780

Total value of all shares of stock

remaining for assessment -4.507,719,064

State assessment (not less than zero) 0

County assessments 0

Residue of total value of stock for

assessment (not < 0) 0

N/A Domestic Shares Tax peraneNS |

- - ——————_—_ ——F

Total Domestic Corporation Tax 1,812,208

Domestic Tax over (under) Foreign Tax 1,244 262

Page 84 of 88

Notes to Financial Data and Calculations

used in "As If Domestic” Analysis prepared

for counsel in anticipation of South

Central Bell case.

BellSouth Telecommunications, Inc.. South

Central Bell Telephone Company; and CSX

Transportation, Inc., were assumed to be public

Code of Alabama 1975, to list their shares of

stock for taxation or to pay ad valorem taxes on

said shares computed pursuant to Sec. 40-14-70,

Code of Alabama 1975.

BellSouth Corporation

For 1986, the entire investment in affiliates was

used for ‘cost of capital stock owned in domestic

corporations’ since no detail was provided in

original return.

For 1990, the total stockholders equity from the

balance sheet attached to the original return

was used for ‘total value of all shares of stock’

even though the original return reflected a

$5,649,902, 127 more in surplus for which the

taxpayer filed a peti

refund stating the amount was overstated for

dividends previously paid throughout 1990;

therefore, $545 was used for franchise tax paid

instead of the original amount of $17,495.06.

Page 85 of 88

Notes to Financial Data and Calculations

used in "As If Domestic” Analysis prepared

for counsel in anticipation of South

Central Bell case.

Notes to Financial Data and Calculations

used in "As If Domestic” Analysis prepared

for counsel in anticipation of South

Central Bell case.

South Central Bell Telephone Company

BellSouth Products, Inc.

BellSouth Telecommunications, Inc.; South

Central Bell Telephone Company; and CSX

Transportation, Inc., were assumed to be public

utilities not required by Sec. 40-21-29, Code of

Alabama 1975, to list their shares of stock for

taxation or to pay ad valore

taxes on said shares computed pursuant to Sec.

40-14-70, Code of Alabama 1975.

BellSouth Services, Inc.

Alabama Cellular Services, Inc.

Sunlink Corporation

BellSouth Financial Services Corporation

For 1989 -1992, the book value of Alabama real

and tangible personal property was obtained by

multiplying the amount for all states by the

tangible property factor from Schedule C, Line 7

of the filed return since the information provided

on the attached

balance sheet was not adequate.

BellSouth Advertising & Publishing

Corporation

BellSouth Resources, Inc.

Page 86 of 88

Page 87 of 88

Notes to Financial Data and Calculations

used in "As If Domestic” Analysis prepared

for counsel in anticipation of South

Central Bell case.

TechSouth, Inc.

Tax Rates used in "As If

Domestic” Analysis prepared for

counsel in anticipation of South

mr CSX Transportation, Inc.

BellSouth Telecommunications, Inc.; South

Central Bell Telephone Company; and CSX

Transportation, Inc., were assumed to be

public utilities not required by Sec. 40-21-29,

Code of Alabama 1975, to list their shares of

stock for taxation or to pay ad valorem taxes

on said shares computed pursuant to Sec.

40-14-70, Code of Alabama 1975.

Page 88 of 88

Central Bell case.

1986 1987

BellSouth Telecommunications, Inc. (Q: 11-12-91)

Domestic Franchise Tax Rate 1.000% 1.000%

Domestic Minimum Franchise Tax A $50.00 $50.00

State Tax Rate (Alabama) 0.650% 0.650%

County Tax Rate (Jefferson) 3.560% 3.560%

Special School Tax (Birmingham) -0.110% -0.110%

City Tax Rate (Birmingham) 2.850% 2.850%

Domestic Shares Tax Rate 6.950% 6.950%

Assessment rate

20.000% 20.000%

1988 1989

Domestic Franchise Tax Rate 1.000% 1.000%

Domestic Minimum Franchise Tax A $50.00 $50.00

State Tax Rate (Alabama) 0.650% 0.650%

County Tax Rate (Jefferson) 3.560% 3.560%

Special School Tax (Birmingham) -0.110% -0.110%

City Tax Rate (Birmingham) 2.850% 2.850%

Domestic Shares Tax Rate 6.950% 6.950%

Assessment rate

Page 1 of 2

20.000% 20.000%

Tax Rates used in "As If

Domestic” Analysis prepared for

counsel in anticipation of South

Central Bell case.

Domestic Franchise Tax Rate

Domestic Minimum Franchise Tax A

State Tax Rate (Alabama)

County Tax Rate (Jefferson)

Special School Tax (Birmingham)

City Tax Rate (Birmingham)

Domestic Shares Tax Rate

Assessment rate

Domestic Franchise Tax Rate

Domestic Minimum Ffanchise Tax A

State Tax Rate (Alabama)

County Tax Rate (Jefferson)

Special School Tax (Birmingham)

City Tax Rate (Birmingham)

Domestic Shares Tax Rate

Assessment rate

Page 2 of 2

1990

1.000%

$50.00

0.650%

3.560%

-0.110%

2.850%

6.950%

1992

1.000%

$50.00

0.650%

3.560%

-0.110%

2.850%

8.250%

20.000%

1991

1.000%

$50.00

0.650%

3.560%

-0.110%

2.850%

6.950%

20.000% 20.000%