Subsequent Tax OpinionRuling

Subsequent Tax OpinionRuling. Means either (i) an opinion of counsel selected by Barnes & Noble, in its sole and absolute discretion, confirming, in form and substance reasonably satisfactory to Barnes & Noble, that, as a consequence of the consummation of a subsequent transaction, no income, gain or loss for U.S. federal income tax purposes will be recognized by Barnes & Noble, the stockholders or former stockholders of Barnes & Noble, or any Barnes & Noble Affiliate with respect to the Distribution, or (ii) an IRS private... letter ruling to the same effect. View More