Liberty Media Corporation Stock Adjustments
- January 13, 2013 - In connection with a spin-off transaction (the Spin-off) effected by the corporation formerly known asLiberty Media Corporation (Old LMC), (i) all of the businesses, assets, and liabilities of Old LMC, other than Starz, LLC,were contributed to Liberty Spinco, Inc., a former subsidiary of Old LMC; (ii) Old LMC was renamed Starz (STRZ);(iii) Liberty Spinco, Inc. was renamed Liberty Media Corporation (New LMC); and (iv) all of the stock of New LMC was distributed on January 11, 2013 to the holders of record of Old LMC stock on the record date.
Click here for Basis Allocation.
- November 28, 2011 - Liberty Media Corporation (Liberty Media) completes the conversion of each share of its Liberty Starz common stock (LSTZA and LSTZB) into 0.88129 of a share of the corresponding series of Liberty Capital common stock (LMCA and LMCB). The tax basis of each 0.88129 of a share of Liberty Media's LMCA and LMCB stock received by holders of Liberty Media's Liberty Starz common stock in the conversion should generally be the same as the tax basis of the share of Liberty Media's LSTZA or LSTZB stock, respectively, that is surrendered in exchange therefor. The tax basis of shares of Liberty Capital common stock held prior to the conversion is not affected by the conversion.
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FORM 8937 RECAPITALIZATION
- September 23, 2011 – Liberty Interactive Corporation (f/k/a Liberty Media Corporation and referred to herein as Liberty Interactive) completes the split-off of Liberty Media Corporation (f/k/a Liberty CapStarz, Inc. and Liberty Splitco, Inc. and referred to herein as Liberty Media). In the split-off, Liberty Interactive redeemed each share of its Liberty Capital and Liberty Starz common stock in exchange for one share of the corresponding series of Liberty Media's Liberty Capital and Liberty Starz common stock, respectively. The ticker symbols for Liberty Media's Liberty Capital and Liberty Starz common stock are the same as the ticker symbols for Liberty Interactive's Liberty Capital and Liberty Starz common stock.
The tax basis of each share of Liberty Media's LCAPA, LCAPB, LSTZA, and LSTZB stock received by holders of Liberty Interactive's Liberty Capital and Liberty Starz common stock in the split-off should generally be the same in each case as the tax basis of the share of Liberty Interactive's LCAPA, LCAPB, LSTZA or LSTZB stock, respectively, that is surrendered in exchange therefor. The tax basis of shares of Liberty Interactive common stock is not affected by the split-off.
This is not tax advice. Please note that the information above is provided solely as a convenience to shareholders. Liberty Interactive does not provide its shareholders with tax advice and the information above is not intended to provide tax advice. Liberty encourages its shareholders to consult with their own tax advisors with respect to their specific questions pertaining to their own tax positions.
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FORM 8937 SPLIT-OFF
- November 19, 2009, Liberty completes split-off of the Liberty Entertainment Inc (LEI) and business combination with DIRECTV (NASDAQ: DTV). Remaining businesses, assets and liabilities not held by LEI remain with Liberty Media and are redesignated as the Liberty Starz group (NASDAQ: LSTZA/B). 1 share of DTV and .1 shares of LSTZA/B issued for each share of LMDIA/B. Click here for basis allocation.
- September 18, 2008, Discovery Holding Company (DHC) completes restructuring into Discovery Communications, Inc. (DCI), and spin off of Ascent Media Corporation (ASCM). Click here for basis allocation.
- March 3, 2008, Liberty Media Corporation completes reclassification of its Liberty Capital group common stock (NASDAQ: LCAPA/B) and issues new tracking stock for the Liberty Entertainment group common stock (NASDAQ: LMDIA/B): 4 shares of LMDIA/B issued for each share of LCAPA/B. Click here for Basis Allocation.
- May 9, 2006, Liberty Media Corporation completes its restructuring and issues two new tracking stocks Liberty Capital group and Liberty Interactive group (NASDAQ:LCAPA/B and LINTA/B, respectively): 0.05 shares of LCAPA/B issued for each 1 share of L/LMC.B held and 0.25 shares of LINTA/B shares issued for each 1 share of L/LMC.B held. Click here for Basis Allocation.
- July 21, 2005, Discovery Holding Company Spin Off from Liberty Media Corporation: 0.10 shares of DISCA/DISCB issued for each 1 share of L/LMC.B. Click here for Basis Allocation.
- June 8, 2004, Liberty Media International Spin Off from Liberty Media Corporation: 0.05 shares of LBTYA/LBTYB issued for each 1 share of L/LMC.B. Click here for Basis Allocation.
- October 31, 2002, Rights Offering to Liberty Media Shareholders: 0.04 transferable subscription rights issued for each share of Series A common stock and Series B common stock held. Each whole right entitled the holder to purchase one share of Series A common stock at a subscription price of $6.00 per share. Please contact the company for further cost basis information.
- August 10, 2001, Liberty Media Split Off from AT&T: Each share of LMG.A/B exchanged on a 1 for 1 basis for shares of the new Liberty Media Corporation Series A and Series B Common stock, trading on the New York Stock Exchange under the symbols LMC.A and LMC.B respectively.
- June 9, 2000, 2-for-1 Stock Split: 1 additional share of LMG.A/B issued for every share of LMG.A/B held
- June 11, 1999, 2-for-1 Stock Split: 1 additional share of LMG.A/B issued for every share of LMG.A/B held
- March 9, 1999, AT&T/TCI Merger: Each share of LBTYA/B exchanged on a 1 for 1 basis for shares of AT&T Liberty Media group A/B, trading on the New York Stock Exchange under the symbols LMG.A/LMG.B
- February 6, 1998, 3-for-2 Stock Split: 1 additional share of LBTYA/B issued for every 2 shares of LBTYA/B held
- January 6, 1998, TCI/Liberty Merger Settlement: 0.01345 share TCOMA for each share of LBTYA held on August 4, 1994; 0.01542 share TCOMB for each share of LBTYB held on August 4, 1994
- January 13, 1997, 3-for-2 Stock Split: 1 additional share of LBTYA for every 2 shares of LBTYA and LBTYB
- August 10, 1995, distribution of Liberty tracking stock: 0.25 shares LBTYA/B issued for each 1 share of TCOMA/B
- August 4, 1994, Merger with TCI: 0.975 shares TCOMA/B for each share of LBTYA/B; 1 share TCOMP for each share of LBTYP
- March 17, 1993, 2-for-1 Stock Split: 1 additional share LBTYA/B issued for each one held
- December 3, 1992, 4-for-1 Stock Split: 3 additional shares LBTYA/B issued for each one held
- March 12, 1992, Liberty recapitalization: 20 shares new LBTYA/B + 2 shares LBTYP issued in exchange for each share of old LBTYA/B
- March 28, 1991, Liberty trades publicly
- March 19,1991, exercise of Liberty Rights: 16 shares TCOMA/B + 1 Right = LBTYA/B
- March 19, 1991, expiration of Liberty Rights: Any not exercised expired with no value
- February 6, 1991, issuance of Liberty Rights: 1 Right for every 200 shares of TCOMA/B
BASIS ALLOCATION FOR LIBERTY MEDIA CORPORATION (LMC) AND STARZ (STRZ) COMMON STOCK
| Record date | 10-Jan-13 | |||
| First trading date | 14-Jan-13 | |||
| In connection with a spin-off transaction (the Spin-off) effected by the corporation formerly known asLiberty Media Corporation (Old LMC), (i) all of the businesses, assets, and liabilities of Old LMC, other than Starz, LLC, were contributed to Liberty Spinco, Inc., a former subsidiary of Old LMC; (ii) Old LMC was renamed Starz (STRZ); (iii) Liberty Spinco, Inc. was renamed Liberty Media Corporation (New LMC); and (iv) all of the stock of New LMC was distributed on January 11, 2013 to the holders of record of Old LMC stock on the record date. | ||||
| LMCA | In the Spin-off, each holder of Old LMC's Series A Liberty Capital common stock (LMCA) receivedone share of New LMC's Series A common stock (New LMCA) for each share of LMCA held by suchholder as of the record date. The old LMCA shares began trading under a new symbol, STRZA, on January 14, 2013. The New LMCA shares shares began trading under the temporary symbol, LMCAD, on January 14, 2013 and will trade under the permanent symbol, LMCA beginning January 22, 2013. | |||
| LMCB | In the Spin-off, each holder of Old LMC's Series B Liberty Capital common stock (LMCB) receivedone share of New LMC's Series B common stock (New LMCB) for each share of LMCB held by suchholder as of the record date. The old LMCB shares began trading under a new symbol, STRZB, on January 14, 2013. The New LMCB shares shares began trading under the temporary symbol, LMCBD, on January 14, 2013 and will trade under the permanent symbol, LMCB beginning January 22, 2013. | |||
| January 14, 2013 Trading Activity | ||||
| Hi | Lo | Average | ||
| LMCADÂ | 110.40 | 107.66 | 109.030 | |
| STRZA | 15.75 | 14.00 | 14.875 | |
| LMCBD* | 110.40 | 107.66 | 109.030 | |
| STRZB | 16.24 | 14.99 | 15.615 | |
| Basis Allocation Example | ||||
| Average | Shares | Total | Percent | |
| LMCAD | 109.030 | 1 | 109.0300 | 87.9948% |
| STRZA | 14.875 | 1 | 14.8750 | 12.0052% |
| LMCBD* | 109.030 | 1 | 109.0300 | 87.4724% |
| STRZB | 15.615 | 1 | 15.6150 | 12.5276% |
*There was no trading of LMCBD shares the week of January 14, 2013. As such, the trading values on January 14, 2013 for LMCAD shares were used for these purposes. This is not tax advice. Please note that the information above is provided solely as a convenience to shareholders. Liberty Media Corporation does not provide its shareholders with tax advice and the information above is not intended to provide tax advice. Liberty Media Corporation encourages its shareholders to consult with their own tax advisors with respect to their specific questions pertaining to their own tax positions. |
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BASIS ALLOCATION FOR DIRECTV (DTV) AND LIBERTY STARZ (LSTZA) COMMON STOCK
| Record date | 19-Nov-09 | |||
| First trading date | 20-Nov-09 | |||
| LMDIA Common | Each share of Liberty Entertainment Series A common stock was exchanged for .9 shares of Liberty Entertainment, Inc. (LEI) Series A common stock and then each whole share of LEI SeriesA common stock was exchanged for 1.1113 shares of DirecTV Class A shares; and .1 of a share of LSTZA common stock | |||
| LMDIB Common | Each share of Liberty Entertainment Series B common stock was exchanged for .9 shares of Liberty Entertainment, Inc. (LEI) Series B common stock and then each whole share of LEI SeriesB common stock was exchanged for 1.1113 shares of DirecTV Class A shares; and .1 of a share of LSTZB common stock | |||
| November 20, 2009 Trading Activity | ||||
| Hi | Lo | Average | ||
| DTV Series A | 32.07 | 30.88 | 31.475 | |
| LSTZA | 50.50 | 48.00 | 49.250 | |
| Basis Allocation for LMDIA Common: | ||||
| Average | Shares | Total | Percent | |
| DTV Series A | 31.475 | 1.00017 | 31.4804 | 86.4718% |
| LSTZA | 49.250 | 0.1 | 4.9250 | 13.5282% |
* As there was no trading activity for the Liberty Starz B prior on November 20, 2009, we are only providing an illustration of the basis allocation information regarding the Liberty Entertainment Series A common shares. There are several potential methods for determining the fair market values of the Liberty Starz Series B shares (generally and with respect to the Series B shares) for the purposes of allocating tax basis following the transactions. Please consult your tax advisor regarding the allocation basis amongst your shares
This is not tax advice. Liberty is providing an example of how to allocate a shareholder's aggregate tax basis in Liberty Entertainment Series A common stock between his or her DIRECTV Class A common shares and Liberty Starz A common shares. This example is provided solely for illustrative purposes and as a convenience because shareholders and their tax advisors may find it useful when establishing their specific tax positions. This example does not include specific basis allocation methodology to fractional shares. Please note that Liberty does not provide its shareholders with tax advice, and this illustrative example is not intended to provide tax advice. Liberty encourages its shareholders to consult with their own tax advisors with their specific questions pertaining to their own tax positions.
BASIS ALLOCATION FOR DISCOVERY HOLDING COMPANY (DHC), DISCOVERY COMMUNICATIONS, INC. (DCI OR DISCOVERY) AND ASCENT MEDIA CORPORATION (ASCM) COMMON STOCK
| Record date | 17-Sep-08 | |||
|---|---|---|---|---|
| First trading date | 18-Sep-08 | |||
| DHC Series A Common | Each share of DHC Series A common stock was exchanged for: | |||
| .5 of a share of DCI A common stock and | ||||
| .5 of a share of DCI C common stock and | ||||
| .05 of a share of ASCM Series A common stock | ||||
| DHC Series B Common | Each share of DHC Series B common stock was exchanged for: | |||
| .5 of a share of DCI B common stock and | ||||
| .5 of a share of DCI C common stock and | ||||
| .05 of a share of ASCM Series B common stock | ||||
| Trade prices on date of exchange | ||||
| Hi | Lo | Average | ||
| DCI Series A | 21.05 | 13.81 | 17.430 | |
| DCI Series B* | 18.96 | 18.96 | 18.960 | |
| DCI Series C | 18.50 | 12.80 | 15.650 | |
| ASCM Series A | 33.81 | 27.21 | 30.510 | |
| ASCM Series B* | ||||
| Basis Allocation Series A* | ||||
| Average | Shares | Total | Percent | |
| DCI Series A | 17.430 | 0.5 | 8.7150 | 48.2411% |
| DCI Series C | 15.650 | 0.5 | 7.8250 | 43.3146% |
| ASCM Series A | 30.510 | 0.05 | 1.5255 | 8.4443% |
| *As there was no trading activity for the DCI Series B prior to September 25, 2008, nor was there trading of the ASCM Series B shares prior to October 3, 2008, we are only providing an illustration of the basis allocation information regarding the DHC Series A common shares. There are several potential methods for determining the fair market values of the DCI and ASCM shares (generally and with respect to the Series B shares) for purposes of allocating tax basis following the transactions. Please consult your tax advisor regarding the allocation of basis amongst your shares. | ||||
| This is not tax advice. Discovery is providing an example of how to allocate a shareholder's aggregate tax basis in DHC Series A common stock between his or her DCI Series A and C shares and ASCM Series A. This example is provided solely for illustrative purposes and as a convenience because shareholders and their tax advisors may find it useful when establishing their specific tax positions. Please remember that Discovery does not provide its shareholders with tax advice, and this illustrative example is not intended to provide tax advice. Discovery encourages its shareholders to consult with their own tax advisors with their specific questions pertaining to their own tax positions. | ||||
BASIS ALLOCATION FOR LIBERTY ENTERTAINMENT (LMDIA) AND LIBERTY CAPITAL (LCAPA) COMMON STOCK
| Record date | 3-Mar-08 |
|---|---|
| First trading date | 4-Mar-08 |
| Liberty Capital Series A Common | Each share of Liberty Capital Series A common stock was exchanged for 4 shares of Liberty Entertainment Series A common stock and 1 share of Liberty Capital Series A common stock |
| Liberty Capital Series B Common | Each share of Liberty Capital Series B common stock was exchanged for 4 shares of Liberty Entertainment Series B common stock and 1 share of Liberty Capital Series B common stock |
| March 4, 2008 Trading Activity | ||||
| Hi | Lo | Average | ||
| LMDI Series A | 26.54 | 24.49 | 25.515 | |
|---|---|---|---|---|
| LCAP Series A | 19.25 | 17.09 | 18.170 | |
| Basis Allocation | ||||
| Average | Shares | Total | Percent | |
| LMDI Series A | 25.515 | 4 | 102.0600 | 84.8873% |
| LCAP Series A | 18.170 | 1 | 18.1700 | 15.1127% |
| ** There was no trading activity for LMDI Series B on March 4, 2008. As a result, we are not providing basis allocation information for the B shares. Please consult your tax advisor with respect to the basis allocation for B shares.Please be sure to check with your own tax advisor as to the particular tax consequences to you of the restructuring. | ||||
BASIS ALLOCATION FOR LIBERTY INTERACTIVE (LINT) AND LIBERTY CAPITAL (LCAP) COMMON STOCK
Record date 9-May-06
First trading date 10-May-06
Liberty Series A Common Each share of Liberty Media Corporation Series A common stock was exchanged for .25 of a share of Liberty Interactive Series A common stock and .05 of a share of Liberty Capital Series A common stock
Liberty Series B Common Each share of Liberty Media Corporation Series B common stock was exchanged for .25 of a share of Liberty Interactive Series B common stock and .05 of a share of Liberty Capital Series B common stock
May 10, 2006 Trading Activity
| Hi | Lo | Average | |
| LINT Series A | 20.25 | 19.21 | 19.730 |
|---|---|---|---|
| LCAP Series A | 80.45 | 73.50 | 76.975 |
| LINT Series B | 20.09 | 19.55 | 19.820 |
| LCAP Series B | 80.75 | 76.45 | 78.600 |
| Basis Allocation | ||||
| Average | Shares | Total | Percent | |
| LINT Series A | 19.730 | 0.25 | 4.9325 | 56.1708% |
| LCAP Series A | 76.975 | 0.05 | 3.8488 | 43.8292% |
| LINT Series B | 19.820 | 0.25 | 4.9550 | 55.7681% |
| LCAP Series B | 78.600 | 0.05 | 3.9300 | 44.2319% |
The trading activity for the Series B common stock excludes the first 30 minutes of trading. This information is intended only as guidance to assist you in your tax calculations. Please be sure to check with your own tax advisor as to the particular tax consequences to you of the restructuring.
BASIS ALLOCATION FOR LIBERTY MEDIA CORPORATION (LMC) AND DISCOVERY HOLDING COMPANY (DHC) COMMON STOCK
| Record date for spin off | July 15, 2005 |
|---|---|
| Record date for the distribution | July 21, 2005 |
| First trading date | July 21, 2005 |
| DHC Class A Common | Each share of LMC Class A Common Stock held on the record date for the distribution will receive .10 of a share of DHC Class A Common Stock. |
| DHC Class B Common | Each share of LMC Class B Common Stock held on the record date for the distribution will receive .10 of a share of DHC Class B Common Stock. |
July 21, 2005 Trading Activity
| Hi | Lo | Average | ||
| LMC Series A | 8.64 | 8.46 | 8.550 | |
| LMC Series B | 10.15 | 8.80 | 9.475 | |
| DHC Series A | 15.10 | 14.20 | 14.650 | |
| DHC Series B | 15.25 | 15.00 | 15.125 | |
| Basis Allocation | ||||
| Average | Shares | Total | Percent | |
| LMC Series A | 8.550 | 1.00 | 8.5500 | 85.3719% |
| DHC Series A | 14.650 | .10 | 1.4650 | 14.6281% |
| LMC Series B | 9.4750 | 1.00 | 9.4750 | 86.2344% |
| DHC Series B | 15.1250 | .10 | 1.5125 | 13.7656% |
This information is intended only as guidance to assist you in your tax calculations. Please be sure to check with your own tax advisor as to the particular tax consequences to you of the LBTY and DHC distributions.
Discovery Holding Company Spin-off - Taxpayer Information Statement
BASIS ALLOCATION FOR LIBERTY MEDIA CORPORATION (“LMC”) AND LIBERTY MEDIA INTERNATIONAL (“LBTY”) COMMON STOCK
| Record date for spin off | 1-Jun-04 | |||
|---|---|---|---|---|
| Record date for the distribution | 7-Jun-04 | |||
| First trading date | 8-Jun-04 | |||
| Transaction : | ||||
| LBTY Class A Common | Each share of LMC Class A Common Stock held on the record date for the distribution will receive .05 of a share of LBTY Class A Common Stock. | |||
| LBTY Class B Common | Each share of LMC Class B Common Stock held on the record date for the distribution will receive .05 of a share of LBTY Class B Common Stock. | |||
| June 8, 2004 Trading Activity | ||||
| Hi | Lo | Average | ||
| LMC Series A | 9.65 | 9.25 | 9.450 | |
| LMC Series B | 11.00 | 10.91 | 10.955 | |
| LBTY Series A | 38.00 | 35.95 | 36.975 | |
| LBTY Series B | 41.98 | 41.25 | 41.615 | |
| Basis Allocation | ||||
| Average | Shares | Total | Percent | |
| LMC Series A | 9.450 | 1.00 | 9.4500 | 83.6376% |
| LBTY Series A | 36.975 | .05 | 1.8488 | 16.3624% |
| LMC Series B | 10.955 | 1.00 | 10.9550 | 84.0381% |
| LBTY Series B | 41.615 | .05 | 2.0808 | 15.9619% |
Liberty Media International Spin-off - Taxpayer Information Statement
Attach to return of shareholders for the year of distribution: Statement of shareholders receiving a distribution of stock in Liberty Media International, Inc. (“LBTY”) (a controlled corporation), pursuant to Treasury Regulations Section 1.355-5(b).
TCI SATELLITE/LIBERTY SATELLITE ADJUSTMENTS
April 1, 2002, Liberty Satellite & Technology 1-for-10 Reverse Stock Split: For every 10 shares of LSATA/LSATB owned, exchange for 1 share of LSTTA/LSTTB respectively.
November 12, 2003, Liberty Satellite & Technology merges with Liberty Media Corporation: Each share of LSTTA/LSTTB exchanged for 0.2750 shares of L/LMC.B.
| Basis Allocation for TCI Group and Liberty Media Group Common Stock | |
| Record date for dividend | 8/10/95 |
|---|---|
| First trading date | 8/11/95 |
| Dividend | |
| TCI Class A Common | Each share of TCI Class A Common Stock will receive as a distribution ¼ share of Tele-Communications, Inc. Series A Liberty Media Group Common Stock. TCI Class A Common Stock is redesignated as Tele-Communications, Inc. Series A TCI Group Common Stock. |
| TCI Class B Common | Each share of TCI Class B Common Stock will receive as a distribution ¼ share of Tele-Communications, Inc. Series B Liberty Media Group Common Stock. TCI Class B Common Stock is redesignated as Tele-Communications, Inc. Series B TCI Group Common Stock. |
| 8/11/95 Trading Activity | ||||
| Hi | Lo | Average | ||
| TCI Series A | 20 | 19.625 | 19.8125 | |
| TCI Series B | 19.625 | 19.625 | 19.625 | |
| Liberty Series A | 25.75 | 25 | 25.375 | |
| Liberty Series B | 25.75 | 25 | 25.375 | |
| Basis Allocation | ||||
| Average | Shares | Total | Percent | |
| TCI Series A | 19.8125 | 1 | 19.8125 | 75.75% |
| Liberty Series A | 25.375 | 0.25 | 6.3438 | 24.25% |
| TCI Series B | 19.625 | 1 | 19.6250 | 75.57% |
| Liberty Series B | 25.375 | 0.25 | 6.3438 | 24.43% |
| Basis Allocation per Share of Common | ||||
| TCI Series A | 75.75% | |||
| Liberty Series A | 97.00% | |||
| TCI Series B | 75.57% | |||
| Liberty Series B | 97.72% | |||
Associated Group, Inc. Merger - For Associated Group, Inc. Shareholders Only
Allocation of Stock Basis between AT&T shares and Liberty Media Group shares
Exchange 1 Associated Group, Inc. A or B share for the following:
.49634 T shares
1.20711 LMG.A shares
| 1/14/2000 | 1/14/2000 | Exchange | Allocation | |||
| High | Low | Average | Ratio | of Value | ||
| T | 55.000 | 53.625 | 54.3125 | 0.49634 | 26.957466 | 29.2088% |
|---|---|---|---|---|---|---|
| LMG.A | 55.125 | 53.125 | 54.125 | 1.20711 | 65.334829 | 70.7912% |
| Total | 92.292295 | 100.0000% | ||||
TCI VENTURES ADJUSTMENTS
March 9, 1999, Liberty/Ventures Combination: Each share of TCIVA/TCIVB exchanged for 0.52 shares of LMG.A/LMG.B
TCI/AT&T ADJUSTMENTS
December 4, 1996, TSAT distribution: 1/10 share TSATA/B for each share of TCOMA/B held
September 10, 1997, TCIVA/B exchange: TCOMA/B shareholders able to elect to switch to TCIVA shares through a dollar-for-dollar exchange. 30% of the basis is allocated to TCIVA/B and 70% is allocated to TCOMA/B.
March 9, 1999, AT&T/TCI Merger: Each share of TCOMA exchanged for 0.7757 shares of AT&T Common (NYSE: T). Each share of TCOMB exchanged for 0.8533 shares of T.
April 15,1999, 3-for-2 Stock Split: 1 additional share of T issued for every 2 shares of T held.
November 15, 2002, AT&T spin off of AT&T Broadband and subsequent merger of AT&T Broadband into Comcast : 0.3235 shares of CMCSA issued for each T held.
IRS Circular 230 Disclaimer: Under applicable Treasury regulations, this notice is not intended or written to be used, and cannot be used, for the purpose of avoiding any penalties.