the holding company for bond insurer is not discussing with creditors and regulators of how to allocate $ 7.3 billion in net operating losses.

A lawyer for Ambac Financial Group Inc. told a bankruptcy judge that the holding company for bond insurer is not discussing with creditors and regulators of how to allocate $ 7.3 billion in net operating losses.

On the other hand, Daniel Filor, attorney for the U.S. attorney's office, told the judge that the government believes that a tax refund dispute Ambac Financial should be transferred from the bankruptcy court in New York federal court district.

Main Ambac insurance unit, Ambac Assurance Corp., was taken by regulators, the insurance commissioner's office in Wisconsin, known as the OIC, is overseeing the rehabilitation of 50 billion U.S. dollars in the portfolio of policies secure residential mortgage-backed securities.

"We are in tripartite negotiations with the committee and the OIC regarding a comprehensive settlement," lawyer Todd Padnos Ambac said U.S. Bankruptcy Judge Shelley Chapman in New York yesterday. He said an agreement could solve "the amount paid by Ambac Assurance to the holding of articles including tax refunds.

Ambac's holding company separately is seeking an injunction to temporarily prohibit the Internal Revenue Service to seize a refund of $ 700 million received to carry back losses in contracts for credit default swap. Also called for a sentence which has no tax liability for 2003 to 2008 and is entitled to maintain a full refund.

At the hearing yesterday, said the U.S. Filor is planning to request moving the competition to a district court, which Ambac may object.

'New and complex "

"New and complex problems of federal tax law are appropriate to go before a federal district court," said Filor.

Ambac has filed for bankruptcy Nov. 8, with liabilities of $ 1.68 million at June 30 on a consolidated basis.

Ambac said in its Chapter 11 bankruptcy was necessary to preserve about $ 7 billion in net operating losses. The IRS has challenged the claims of both companies tax deductions that are said to be generated by those losses.

The IRS has agreed not to take enforcement action against Ambac or its subsidiaries without giving five days' notice. The agreement will remain in effect until a hearing to decide whether Ambac can get a ruling.

The agreement requires the IRS to send a response to the motion of December 31 Ambac, and Ambac to meet again on January 18.

On the other hand, Chapman approved the hiring of Blackstone Advisory Partners LP as financial advisor, Dewey & LeBoeuf LLP as bankruptcy counsel, and Togut, Segal & Segal as attorney conflicts LLLP. Morrison & Foerster LLP was also approved as counsel for the official committee of unsecured creditors, and Lazard Freres & Co. as financial adviser to the committee.

The case is In re holding company Ambac Financial Group Inc., 10-15973, U.S. Bankruptcy Court, Southern District of New York (Manhattan).