# Opposition Brief — South Central Bell Telephone Co. v. Alabama > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/brief%3Amicro_IA40385014_0188%3A03 ## Record - **Collection:** Supreme Court brief - **Document type:** Opposition Brief - **Published:** January 1, 1999 - **Citation:** 526 U.S. 160 ## Text 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