. the nols are subject to limitations as promulgated under section 382 of the internal revenue code of 1986 , as amended ( the 201ccode 201d ) . section 382 of the code limits the amount of acquired nols that we can use on an annual basis to offset future u.s . consolidated taxable income . valuation allowances and unrecognized tax benefits were recorded against these nols in the amount of $ 484 million ( $ 170 million tax- effected ) as part of the purchase price allocation