IN THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

) Chapter 11 In re: COLLINS & AIKMAN CORPORATION, et al.1 Debtors. ) ) ) ) ) ) ) Case No. 05-55927 (SWR) (Jointly Administered) (Tax Identification #13-3489233) Honorable Steven W. Rhodes

FIRST INTERIM FEE APPLICATION OF DELOITTE TAX LLP AS TAX SERVICE PROVIDERS FOR THE DEBTORS FOR ALLOWANCE OF INTERIM COMPENSATION FOR SERVICES RENDERED AND EXPENSES INCURRED FROM SEPTEMBER 1, 2005 THROUGH DECEMBER 31, 2005
Name of Applicant: Date of Retention: Date of Entry of Order Authorizing Employment Period for Which Compensation and Reimbursement is Sought:
1

DELOITTE TAX LLP Nunc Pro Tunc to September 1, 2005 November 10, 2005 September 1, 2005

September 1, 2005 through and including

The Debtors in the jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc., Case No. 05-55949; Becker Group, LLC (d/b/a/ Collins & Aikman Premier Mold), Case No. 05-55977; Brut Plastics, Inc., Case No. 0555957; Collins & Aikman (Gibraltar) Limited, Case No. 05-55989; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation), Case No. 05-55952; Collins & Aikman Asset Services, Inc., Case No. 05-55959; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.), Case No. 05-55965; Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.), Case No. 05-55991; Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.), Case No. 05-55958; Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.), Case No. 05-55956; Collins & Aikman Automotive International, Inc., Case No. 05-55980; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.), Case No. 05-55985; Collins & Aikman Automotive Mats, LLC, Case No. 05-55969; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.), Case No. 05-55978; Collins & Aikman Automotive Services, LLC, Case No. 05-55981; Collins & Aikman Canada Domestic Holding Company, Case No. 05-55930; Collins & Aikman Carpet & Acoustics (MI), Inc., Case No. 05-55982; Collins & Aikman Carpet & Acoustics (TN), Inc., Case No. 05-55984; Collins & Aikman Development Company, Case No. 05-55943; Collins & Aikman Europe, Inc., Case No. 05-55971; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.), Case No. 05-55963; Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.), Case No. 05-55976; Collins & Aikman Interiors, Inc., Case No. 05-55970; Collins & Aikman International Corporation, Case No. 05-55951; Collins & Aikman Plastics, Inc., Case No. 05-55960; Collins & Aikman Products Co., Case No. 05-55932; Collins & Aikman Properties, Inc., Case No. 05-55964; Comet Acoustics, Inc., Case No. 05-55972; CW Management Corporation, Case No. 05-55979; Dura Convertible Systems, Inc., Case No. 05-55942; Gamble Development Company, Case No. 05-55974; JPS Automotive, Inc. (d/b/a PACJ, Inc.), Case No. 05-55935; New Baltimore Holdings, LLC, Case No. 0555992; Owosso Thermal Forming, LLC, Case No. 05-55946; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.), Case No. 05-55948; Wickes Asset Management, Inc., Case No. 05-55962; and Wickes Manufacturing Company, Case No. 05-55968.

0W[;&"-

0555927060213000000000004

$A

December 31, 20052 Amount of Compensation Sought As Actual, Necessary and Reasonable: Amount of Expense Reimbursement Sought as Actual, Necessary, and Reasonable: This is:

$162,749

$732 A First Interim Fee Application

Blended Applicable Hourly Rate of Professional And Paraprofessionals $422.65

No monthly statement has been served on the Debtors by Deloitte Tax and no payments have been made to Deloitte Tax for its services rendered.

PROFESSIONALS RENDERING SERVICES FOR WHICH COMPENSATION IS BEING SOUGHT From September 1, 2005 through December 31, 2005
VALUE OF SERVICES RENDERED AT APPLICABLE HOURLY RATES 25,785 675 1,080 12,150 675 1,350 675 1,726 11,341 2,499 5,446 951 2,520 4,366 1,801 22,944 23,894 397 1,199 18,151 1,626 203 5,292 3,193 2,280 8,600 858 261 86 17 34 645 34 $ 162,749

NAME HOFFMAN, DAVID N BOULET, WILLIAM P JR WOERTZ, KEVIN DAVID BOOCOCK, STEPHEN W CRYAN, THOMAS M DOUGHERTY, JAMES A GANNON, JAMES M SHEKELL, SCOTT L SHEKELL, SCOTT L ZIMET, LEE G GERSTEL, KENNETH A ATHANAS, JOHN A JORAH, CHRISTINE L WRIGHT, CHARLES T PEZZETTI, MICHAEL J FRIESTEDT, THEIA A GUNDRUM, JENNIFER M URBANIAK, JULIE JOHNSON ROWE, LEONARD A II STARZYNSKI, STEVEN D CATANA, TARA M KROZEK, DEREK J GUILLEN, JOHANNA TERESA CASSILL, REBECCA L TEGGART, MARK JOHN JR BRIDENSTINE, TRAVIS J NELSON, CARY KEN LYONS, CYNTHIA D PATTERSON, MARY ANN KONSTANTINIDIS, ANDRIANA DONNA OLIVER, KRISTINE T MOMIN, JASMINE SULTANALI BELL, RENEE ELISE TOTAL HOURS AND FEES SOUGHT HEREIN

POSITION Partner Director Partner Director Director Director Partner Partner Partner Director Senior Manager Senior Manager Senior Manager Senior Manager Senior Manager Manager Manager Manager Manager Senior Senior Senior Senior Senior Staff Staff Staff Staff Staff Staff Staff Staff Staff

HOURS 38.20 1.00 1.60 18.00 1.00 2.00 1.00 3.00 21.00 3.70 9.90 2.00 5.60 9.70 4.00 48.30 50.30 1.10 2.50 48.40 6.00 0.70 37.80 8.50 11.40 35.10 3.50 4.00 1.30 0.25 0.50 3.22 0.50 385.07

RATE 675 675 675 675 675 675 675 575 540 675 550 475 450 450 450 475 475 360 475 375 270 290 140 375 200 245 245 65 65 65 65 200 65 422.65

(effective blended rate)

IN THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION ) Chapter 11 In re: COLLINS & AIKMAN CORPORATION, et al.1 Debtors. ) ) ) ) ) ) ) Case No. 05-55927 (SWR) (Jointly Administered) (Tax Identification #13-3489233) Honorable Steven W. Rhodes

FIRST INTERIM FEE APPLICATION OF DELOITTE TAX LLP AS TAX SERVICE PROVIDERS FOR THE DEBTORS FOR ALLOWANCE OF INTERIM COMPENSATION FOR SERVICES RENDERED AND EXPENSES INCURRED FROM SEPTEMBER 1, 2005 THROUGH DECEMBER 31, 2005 Deloitte Tax LLP (Deloitte Tax), tax service providers for the above-captioned debtors (collectively, the Debtors), pursuant to sections 330(a) and 331 of the Bankruptcy Code, 11 U.S.C. 101-1330 (the Bankruptcy Code) and Rule 2016 of the Federal Rules of Bankruptcy Procedure (the Bankruptcy Rules), Rules 2016-1 and 9014-1 of the Local Rules for the Bankruptcy Court, Eastern District of Michigan (the
1

The Debtors in the jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc., Case No. 05-55949; Becker Group, LLC (d/b/a/ Collins & Aikman Premier Mold), Case No. 05-55977; Brut Plastics, Inc., Case No. 0555957; Collins & Aikman (Gibraltar) Limited, Case No. 05-55989; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation), Case No. 05-55952; Collins & Aikman Asset Services, Inc., Case No. 05-55959; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.), Case No. 05-55965; Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.), Case No. 05-55991; Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.), Case No. 05-55958; Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.), Case No. 05-55956; Collins & Aikman Automotive International, Inc., Case No. 05-55980; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.), Case No. 05-55985; Collins & Aikman Automotive Mats, LLC, Case No. 05-55969; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.), Case No. 05-55978; Collins & Aikman Automotive Services, LLC, Case No. 05-55981; Collins & Aikman Canada Domestic Holding Company, Case No. 05-55930; Collins & Aikman Carpet & Acoustics (MI), Inc., Case No. 05-55982; Collins & Aikman Carpet & Acoustics (TN), Inc., Case No. 05-55984; Collins & Aikman Development Company, Case No. 05-55943; Collins & Aikman Europe, Inc., Case No. 05-55971; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.), Case No. 05-55963; Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.), Case No. 05-55976; Collins & Aikman Interiors, Inc., Case No. 05-55970; Collins & Aikman International Corporation, Case No. 05-55951; Collins & Aikman Plastics, Inc., Case No. 05-55960; Collins & Aikman Products Co., Case No. 05-55932; Collins & Aikman Properties, Inc., Case No. 05-55964; Comet Acoustics, Inc., Case No. 05-55972; CW Management Corporation, Case No. 05-55979; Dura Convertible Systems, Inc., Case No. 05-55942; Gamble Development Company, Case No. 05-55974; JPS Automotive, Inc. (d/b/a PACJ, Inc.), Case No. 05-55935; New Baltimore Holdings, LLC, Case No. 0555992; Owosso Thermal Forming, LLC, Case No. 05-55946; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.), Case No. 05-55948; Wickes Asset Management, Inc., Case No. 05-55962; and Wickes Manufacturing Company, Case No. 05-55968.

Local Rules), the Retention Order (as defined below) and the Administrative Order (as defined below) files this application (the First Interim Fee Application) for, and hereby applies for entry of an order, substantially in the form of Exhibit F, allowing it interim allowance of, compensation for professional services performed by Deloitte Tax for the period from September 1, 2005 through December 31, 2005 (the Compensation Period) and for reimbursement of expenses associated therewith. represents: Jurisdiction 1. This Court has jurisdiction to consider this First Interim Application Deloitte Tax respectfully

pursuant to 28 U.S.C. 157 and 1334. Consideration of this First Interim Application is a core proceeding pursuant to 28 U.S.C. 157(b)(2). Venue of this case is proper in this district pursuant to 28 U.S.C. 1408 and 1409, respectively. The statutory predicate for the relief requested herein is sections 330 and 331 of the Bankruptcy Code. Background 2. On May 17, 2005 (the Petition Date), the Debtors filed their voluntary

petitions for relief under chapter 11 of the Bankruptcy Code. The Debtors are operating their businesses and managing their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No trustee or examiner has been appointed in these cases. On the Petition Date, the Court entered an order jointly

administering these case pursuant to the Bankruptcy Code. 3. On May 24, 2005, the United States trustee appointed an official

committee of unsecured creditors pursuant to section 1102 of the Bankruptcy Code (the Committee).

4.

The Debtors and their non-debtor affiliates are leading global suppliers of

automotive components, systems and modules to all of the worlds largest vehicle manufacturers, including DaimlerChrysler AG, Ford Motor Company, General Motors Corporation, Honda Motor Company, Inc., Nissan Motor Company Unlimited, Porsche Cars GB, Renault Createur DAutomobiles, Toyota SA and Volkswagen AG. Retention of Deloitte Tax LLP
5.

On November 10, 2005 the Court entered an Order Approving the

Employment of Deloitte Tax LLP as Tax Service Providers Nunc Pro Tunc to September 1, 2005 (the Retention Order), pursuant to a retention application submitted by the Debtors (the Retention Application). A copy of the Retention Order is attached hereto as Exhibit A. Pursuant to the Deloitte Tax Retention Order, Deloitte Tax was authorized to perform and to be compensated by the Debtors, subject to application to this Court as set forth therein, for various tax services, including expatriate tax services, contingent fee strategic review services and other bankruptcy-related tax consulting services, and, inter alia, tax advisory services for the Debtors related to debt discharge issues arising in connection with this case. The Retention Order also authorized Deloitte Taxs

reimbursement for actual and necessary expenses incurred, subject to application to this Court as set forth therein. Summary of Professional Compensation and Reimbursement of Expenses Requested 6. Except as is clarified herein, Deloitte Tax has striven to prepare the First

Interim Fee Application in accordance with applicable guidelines for fees and disbursements of professionals in the Eastern District of Michigan bankruptcy cases, adopted by the Court (the Local Guidelines), or United States Trustee guidelines for

reviewing applications for compensation and reimbursement of expenses filed under 11 U.S.C. 330 (the UST Guidelines)], and with the interim compensation Administrative Order Establishing Procedures for Monthly Compensation and Reimbursement of Expenses of Professionals and Official Committee Members [Docket No. 290] (the Administrative Order, and together with the Local Guidelines and the UST Guidelines, the Guidelines). 7. Deloitte Tax seeks allowance of interim compensation for the tax services

(the Tax Services) rendered to the Debtors during the Compensation Period in the amount of $162,749 as is more fully described below. Deloitte Tax is also seeking allowance of interim reimbursement of expenses incurred in connection with the Tax Services rendered to the Debtors during the Compensation Period in the amount of $732, and reserves the right to seek trailing expenses, including, without limitation, for December, 2005, if any, in a future interim fee application. 8. The compensation for fees being sought in this First Interim Fee

Application is thus only for 385.07 hours of the Tax Services at a $422.65 blended hourly rate in the total amount of $162,749 for the Compensation Period and, as noted above, reflects time incurred in connection with Chapter 11 administration matters. 9. Deloitte Tax has received no promises regarding compensation in these

Chapter 11 cases other than in accordance with the Bankruptcy Code and as set forth in the Retention Application. In respect of the services to be provided by Deloitte Tax to the Debtors in these Chapter 11 cases, Deloitte Tax has no agreement with any nonaffiliated entity to share any revenues from such services..

10.

Deloitte Taxs fees in these cases are billed in accordance with the existing

compensation arrangements set forth in the engagement letter(s) between the Debtors and Deloitte Tax in effect during the Compensation Period. The rates Deloitte Tax charges for the services rendered by professionals in these Chapter 11 cases are consistent with the rates Deloitte Tax charges for professional services rendered in comparable nonbankruptcy-related matters. Such fees are reasonable based on the customary

compensation charged by comparably skilled practitioners in comparable non-bankruptcy cases in a competitive professional services market. 11. Pursuant to the Guidelines, supplied herewith is a schedule setting forth all

professionals and paraprofessionals who have performed services in these Chapter 11 cases during the Compensation Period for which interim compensation is being sought, each such individuals position with Deloitte Tax the hourly rate charged by Deloitte Tax for services performed by each such individual, and the aggregate number of hours expended by each such individual. 12. Pursuant to the Guidelines, annexed hereto as Exhibit B is a summary

statement of the number of hours of services rendered by each professional and the hourly rate of each by project categories for the services performed by Deloitte Tax during the Compensation Period. Exhibit C is an itemized time record, in chronological order, of each specific service for which an award of compensation is sought. This is in the form of a spreadsheet reflecting detailed descriptions of services rendered and time thereby expended (in increments on one-tenth of an hour) sorted by each professional providing the services by day. Exhibit D contains the biographical statements of the engagement partners for the Tax Services rendered. Exhibit E is an itemized statement

of expenses reflecting the actual and necessary expenses incurred by Deloitte Tax LLP in the provision of services to the Debtor for which expenses reimbursement is sought. 13. Due to the timing of its appointment, Deloitte Tax has not submitted

monthly fee statements requesting compensation of professional services during the Compensation Period (Monthly Fee Statement) to the Debtors, for the months of September 2005, October 2005, November 2005, and December 2005, nor has it been paid to date for any of its post-petition services or any of its expenses. In lieu thereof Deloitte Tax is accordingly supplying requisite monthly-statement level detail in the supporting schedules to this First Interim Fee Application. As Deloitte Tax has not been compensated for any Tax services rendered during the Compensation Period, it respectfully requests that the Debtor be authorized to pay it the aggregate fees due, subject to any hold backs, and reimburse it for its expenses upon the Courts approval of this First Interim Fee Application. 14. As noted above, the daily contemporaneous activity descriptions of each

of the Deloitte Tax professionals and paraprofessionals providing services to the Debtors for the First Interim Fee Application pertaining to the Compensation Period from September 1, 2005 through December 31, 2005 is reflected on Exhibit C hereto. 15. Deloitte Tax has attempted to include in this First Interim Fee Application Delays in processing such time and

all time relating to the Compensation Period.

receiving invoices for certain expenses, however, do occur. Accordingly, Deloitte Tax reserves the right to request compensation and reimbursement for fees and trailing expenses, if any, incurred during the period September 1, 2005 through and including

December 31, 2005, but not reflected in this First Interim Fee Application, in future fee applications.

Reasonable and Necessary Services Rendered by Deloitte Tax (Categorized by Subject Matter) 16. In addition to the detail supplied in Exhibit C, the description of services

of Exhibit B further summarizes the Tax Services rendered by Deloitte Tax during the Compensation Period (including for Chapter 11 administration), and highlights the benefits conferred upon the Debtors and their estates and creditors as a result of Deloitte Taxs services. The specific professional services that Deloitte Tax rendered during the Compensation Period are listed at Exhibit B which is a summary of the hours billed by subject matter during the Compensation Period and include these categories: (1) general corporate history, (2) bankruptcy plan details, (3) Internal Revenue Code (IRS) Section 382 limitation analysis, (4) international assignments services consulting, (5) loan staff arrangement state and local tax consulting, (6) IRS audit support, (7) assistance regarding Canadian anti-abuse legislation, (8) internal and external planning meetings, and (9) Chapter 11 administration, including, but not limited to, billing and tracking time in anticipation of fee application preparation. Allowance of Compensation 17. Section 331 of the Bankruptcy Code allows a bankruptcy court to

authorize interim compensation for [a] trustee, an examiner, a debtors attorney, or any professional person employed under section 327 or 1103 of this title not more than once every 120 days after an order for relief in a case under this title [.] Instruction for Section 331 disbursements is provided under section 330 of this title.

18.

Section 330 of the Bankruptcy Code authorizes the bankruptcy court to

award a trustee, an examiner or a professional employed pursuant to 11 U.S.C. 327, reasonable compensation for its services and reimbursement of its expenses. Specifically, Section 330 of the Bankruptcy Code provides as follows: (a)(1) After notice to the parties in interest and to the United States Trustee and a Hearing, and subject to sections 326, 328, and 329, the court may award to a trustee, an examiner, ombudsman, a professional person employed under section 327 or 1103

(A) reasonable compensation for actual, necessary services rendered by the trustee, examiner, professional person, or attorney and by any paraprofessional person employed by such person; and (B) 11 U.S.C. 330(a)(1). 19. Section 330(a)(3) of the Bankruptcy Code provides that in determining the reimbursement for actual, necessary expenses.

amount of reasonable compensation to be awarded, the court should consider the nature, extent and value of the services rendered to the estate, taking into account all relevant factors, including: (A) (B) the time spent on such services; the rates charged for such services;

(C) whether the services were necessary to the administration of, or beneficial at the time, at which the service was rendered toward the completion of, a case under this title; (D) whether the services were performed within a reasonable amount of time commensurate with the complexity, importance, and nature of the problem, issue, or task addressed; and . . . (F) whether the compensation is reasonable, based on the customary compensation charged by comparably skilled practitioners in cases other than cases under this title.

11 U.S.C. 330(a)(3)(A)-(E). 20. As analyzed below, Deloitte Tax respectfully submits that the elements

governing awards of compensation justify the allowance requested.

(1) 21.

Time and Labor Required During the Compensation Period, 385.1 recorded hours have been

expended by the relevant professionals or other personnel in providing the hourly-rate Tax Services. Exhibit C hereto details the time and labor expended by these

professionals or other personnel on behalf of the Debtors and identifies the hours that are being billed.

(2) 22.

Rates Charged for such Services During the Compensation Period, Deloitte Taxs applicable hourly billing

rates or those of Deloitte Tax personnel involved ranged from $540.00 to $675.00 per hour for partners, principals and directors, $450.00 to $550.00 per hour for senior managers, $360.00 to $475.00 per hour for managers, $270.00 to $375.00 per hour for seniors, $200.00 to $240.00 per hour for staff, and $65.00 per hour for administrative personnel. Based on the recorded billable hours expended by Deloitte Taxs

professionals, the average hourly billing rate for such professional services was approximately $422.65 including paraprofessionals. 23. The applicable amounts charged to the Debtors for the particular services

rendered are consistent with the approximate rates charged other clients of Deloitte Tax for comparable services in similar situations.

(3)

Necessity of the Services and Benefit to the Estate As detailed above, services provided to the Debtors were necessary for the

26.

Debtors business operations and conferred substantial benefit on the Debtors estates. Chapter 11 administration services were a prerequisite to continuing to provide postpetition services to the Debtors. (4) 27. Customary Compensation Deloitte Tax relies on the Courts experience and knowledge with respect

to the compensation awards in similar cases. Given that frame of reference, Deloitte Tax submits that, in light of the circumstances of the case and the substantial benefits derived from Deloitte Taxs assistance, compensation in the amount requested is fair and reasonable. (5) Whether Services Were Performed in a Reasonable Amount of Time Deloitte Tax believes that Tax Services were performed in a reasonable

28.

amount of time, given the complexity of the issues and the scope of services involved and that the time expended on various tasks was necessary and appropriate. (6) 29. Whether Compensation is Reasonable The Tax Services that have been rendered in an efficient manner by

professionals with extensive experience in providing services within the scope of the Retention Order. 30. Deloitte Tax further believes that the compensation sought for the Tax

Services rendered in connection with these Chapter 11 cases is reasonable and commensurate with those rates charged by comparable professional services firms.

10

31.

As set forth in more detail above, Deloitte Taxs time has been

appropriately spent in this case. Based upon Deloitte Taxs blended hourly rate of $422.65 for professionals (including paraprofessionals), Deloitte Tax submits that its applicable rates are indeed comparable to those prevailing in the relevant professional services market. Therefore, taking into consideration the time and labor spent, the nature and extent of the professional services rendered and the nature of these proceedings, Deloitte Tax believes the allowance asked for is reasonable. 32. In sum, based on the factors to be considered under sections 330 and 331

of the Bankruptcy Code, the allowance in full of Deloitte Taxs compensation herein is justified. Disbursements 33. For this Compensation Period, in connection with its provision of the Tax

Services, Deloitte Tax is seeking in this First Interim Fee Application reimbursement for its reasonable and necessary expenses incurred on behalf of the Debtors during June through September, 2005 in the aggregate amount of $732. 34. In summary, by this First Interim Fee Application, Deloitte Tax requests

allowance and payment of any outstanding amounts of fees and expenses in the total amount of $163,481 consisting of $162,749 for the actual, reasonable, and necessary professional services rendered by Deloitte Tax on behalf of the Debtors (representing 100% of fees for services rendered) and $732 for actual and necessary expenses (representing 100% of the expenses incurred by Deloitte Tax). Application of a 20% holdback to the actual amount to be paid by the Debtors at this time upon the Courts

11

approval of this First Interim Fee Application would result in a payment of $130,199 for the tax services at this time. WHEREFORE, Deloitte Tax respectfully requests entry of an order, substantially in the form attached hereto as Exhibit F (a) allowing an administrative expense claim for Deloitte Tax for compensation and reimbursement for its fees and expenses incurred during the Compensation Period, (b) authorizing and directing payment of such amounts, and (c) granting such other and further relief as is just and proper.

Dated:

February 13, 2006 Detroit, Michigan

Respectfully submitted, DELOITTE TAX LLP

/s/ Scott Shekell Scott Shekell, Partner 600 Renaissance Center, Suite 900 Detroit, MI 48243-1595 Telephone: 313-396-3297 Facsimile: 313-392-7794 Tax Service Providers for the Debtors

12

IN THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

) Chapter 11 In re: COLLINS & AIKMAN CORPORATION, et al Debtors.

1

) ) ) ) ) ) )

Case No. 05-55927 (SWR) (Jointly Administered) (Tax Identification #13-3489233) Honorable Steven W. Rhodes

ORDER GRANTING FIRST INTERIM FEE APPLICATION OF DELOITTE TAX LLP FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR SERVICES RENDERED AS TAX SERVICE PROVIDERS FOR THE DEBTORS FOR THE PERIOD SEPTEMBER 1, 2005 THROUGH DECEMBER 31, 2005 Upon the first interim fee application (the First Interim Fee Application)2 of Deloitte Tax LLP (Deloitte Tax) for compensation and reimbursement of expenses for services rendered as tax service providers for the Debtors for the period September 1, 2005 through December 31, 2005; it appearing that the relief requested is in the best
1

The Debtors in the jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc., Case No. 05-55949; Becker Group, LLC (d/b/a/ Collins & Aikman Premier Mold), Case No. 05-55977; Brut Plastics, Inc., Case No. 0555957; Collins & Aikman (Gibraltar) Limited, Case No. 05-55989; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation), Case No. 05-55952; Collins & Aikman Asset Services, Inc., Case No. 05-55959; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.), Case No. 05-55965; Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.), Case No. 05-55991; Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.), Case No. 05-55958; Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.), Case No. 05-55956; Collins & Aikman Automotive International, Inc., Case No. 05-55980; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.), Case No. 05-55985; Collins & Aikman Automotive Mats, LLC, Case No. 05-55969; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.), Case No. 05-55978; Collins & Aikman Automotive Services, LLC, Case No. 05-55981; Collins & Aikman Canada Domestic Holding Company, Case No. 05-55930; Collins & Aikman Carpet & Acoustics (MI), Inc., Case No. 05-55982; Collins & Aikman Carpet & Acoustics (TN), Inc., Case No. 05-55984; Collins & Aikman Development Company, Case No. 05-55943; Collins & Aikman Europe, Inc., Case No. 05-55971; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.), Case No. 05-55963; Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.), Case No. 05-55976; Collins & Aikman Interiors, Inc., Case No. 05-55970; Collins & Aikman International Corporation, Case No. 05-55951; Collins & Aikman Plastics, Inc., Case No. 05-55960; Collins & Aikman Products Co., Case No. 05-55932; Collins & Aikman Properties, Inc., Case No. 05-55964; Comet Acoustics, Inc., Case No. 05-55972; CW Management Corporation, Case No. 05-55979; Dura Convertible Systems, Inc., Case No. 05-55942; Gamble Development Company, Case No. 05-55974; JPS Automotive, Inc. (d/b/a PACJ, Inc.), Case No. 05-55935; New Baltimore Holdings, LLC, Case No. 0555992; Owosso Thermal Forming, LLC, Case No. 05-55946; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.), Case No. 05-55948; Wickes Asset Management, Inc., Case No. 05-55962; and Wickes Manufacturing Company, Case No. 05-55968. Capitalized terms but not otherwise defined herein shall have the meanings set forth in the First Interim Fee Application.

interest of the Debtors estates, their creditors and other parties in interest; it appearing that the Court has jurisdiction over this matter pursuant to 28 U.S.C 157 and 1334; it appearing that this proceeding is a core proceeding pursuant to 28 U.S.C. 157 (b)(2); it appearing that venue of this proceeding and this Motion in the District is proper pursuant to 28 U.S.C. 1409 and 1409; notice of this First Interim Fee Application and the opportunity for a hearing on this First Interim Fee Application was appropriate under the particular circumstances and that no other for further notice need be given; and after due deliberation and sufficient cause appearing therefore, it is hereby ORDERED 1. The First Interim Fee Application is granted in its entirety, on an interim basis. 2. The Court allows an administrative expense claim for Deloitte Tax in the amount of $162,749 for necessary professional services rendered and $732 for expenses incurred during the Compensation Period. 3. The Debtors are hereby authorized and directed to pay the outstanding amount of the sums described in paragraph 2 hereof representing 100% of the unpaid fees (subject to the 20% hold back) pursuant to the Administrative Order governing interim compensation and 100% of the unpaid expenses for the period of September 1, 2005 through December 31, 2005. 4. The Debtors are authorized to take all actions necessary to effectuate the relief granted pursuant to this Order in accordance with the First Interim Fee Application. 5. The terms and conditions of this Order shall be immediately effective and enforceable upon its entry.

Order Granting First Interim Fee Application

6. The Court retains jurisdiction with respect to all matters arising from or related to the implementation of this Order.

Order Granting First Interim Fee Application

IN THE UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION In re: COLLINS & AIKMAN CORPORATION, et al.1 Debtors. ) ) ) ) ) ) ) ) Chapter 11 Case No. 05-55927 (SWR) (Jointly Administered) (Tax Identification #13-3489233) Honorable Steven W. Rhodes

NOTICE AND OPPORTUNITY TO RESPOND TO FIRST INTERIM FEE APPLICATION OF DELOITTE TAX LLP AS TAX SERVICE PROVIDERS FOR THE DEBTORS FOR ALLOWANCE OF INTERIM COMPENSATION FOR SERVICES RENDERED AND EXPENSES INCURRED FROM SEPTEMBER 1, 2005 THROUGH DECEMBER 31, 2005 PLEASE TAKE NOTICE THAT Deloitte Tax LLP (Deloitte) has filed its First Interim Fee Application of Deloitte Tax LLP as Tax Service Providers for the Debtors for Allowance of Interim Compensation for Services Rendered and Expenses Incurred from September 1, 2005 through December 31, 2005 (the Application) pursuant to the

Administrative Order Establishing Procedures for Monthly Compensation and Reimbursement of

The Debtors in the jointly administered cases include: Collins & Aikman Corporation; Amco Convertible Fabrics, Inc., Case No. 05-55949; Becker Group, LLC (d/b/a/ Collins & Aikman Premier Mold), Case No. 05-55977; Brut Plastics, Inc., Case No. 05-55957; Collins & Aikman (Gibraltar) Limited, Case No. 05-55989; Collins & Aikman Accessory Mats, Inc. (f/k/a the Akro Corporation), Case No. 05-55952; Collins & Aikman Asset Services, Inc., Case No. 05-55959; Collins & Aikman Automotive (Argentina), Inc. (f/k/a Textron Automotive (Argentina), Inc.), Case No. 05-55965; Collins & Aikman Automotive (Asia), Inc. (f/k/a Textron Automotive (Asia), Inc.), Case No. 0555991; Collins & Aikman Automotive Exteriors, Inc. (f/k/a Textron Automotive Exteriors, Inc.), Case No. 05-55958; Collins & Aikman Automotive Interiors, Inc. (f/k/a Textron Automotive Interiors, Inc.), Case No. 05-55956; Collins & Aikman Automotive International, Inc., Case No. 05-55980; Collins & Aikman Automotive International Services, Inc. (f/k/a Textron Automotive International Services, Inc.), Case No. 05-55985; Collins & Aikman Automotive Mats, LLC, Case No. 05-55969; Collins & Aikman Automotive Overseas Investment, Inc. (f/k/a Textron Automotive Overseas Investment, Inc.), Case No. 05-55978; Collins & Aikman Automotive Services, LLC, Case No. 05-55981; Collins & Aikman Canada Domestic Holding Company, Case No. 05-55930; Collins & Aikman Carpet & Acoustics (MI), Inc., Case No. 05-55982; Collins & Aikman Carpet & Acoustics (TN), Inc., Case No. 05-55984; Collins & Aikman Development Company, Case No. 05-55943; Collins & Aikman Europe, Inc., Case No. 05-55971; Collins & Aikman Fabrics, Inc. (d/b/a Joan Automotive Industries, Inc.), Case No. 05-55963; Collins & Aikman Intellimold, Inc. (d/b/a M&C Advanced Processes, Inc.), Case No. 05-55976; Collins & Aikman Interiors, Inc., Case No. 05-55970; Collins & Aikman International Corporation, Case No. 05-55951; Collins & Aikman Plastics, Inc., Case No. 05-55960; Collins & Aikman Products Co., Case No. 05-55932; Collins & Aikman Properties, Inc., Case No. 0555964; Comet Acoustics, Inc., Case No. 05-55972; CW Management Corporation, Case No. 05-55979; Dura Convertible Systems, Inc., Case No. 05-55942; Gamble Development Company, Case No. 05-55974; JPS Automotive, Inc. (d/b/a PACJ, Inc.), Case No. 05-55935; New Baltimore Holdings, LLC, Case No. 05-55992; Owosso Thermal Forming, LLC, Case No. 05-55946; Southwest Laminates, Inc. (d/b/a Southwest Fabric Laminators Inc.), Case No. 05-55948; Wickes Asset Management, Inc., Case No. 05-55962; and Wickes Manufacturing Company, Case No. 05-55968.

K&E 10964523.1

Expenses for Professionals and Official Committee Members dated June 9, 2005 [Docket No. 290] (the Compensation Procedures Order). PLEASE TAKE FURTHER NOTICE THAT your rights may be affected. You may wish to review the Application and discuss it with your attorney, if you have one in these cases. (If you do not have any attorney, you may wish to consult one.) PLEASE TAKE FURTHER NOTICE THAT in accordance with the Compensation Procedures Order, if you wish to object to the Court granting the relief sought in the Application, or if you want the Court to otherwise consider your views on the Application, no later than February 28, 2006 at 4:00 p.m. prevailing Eastern Time, or such shorter time as the Court may hereafter order and of which you may receive subsequent notice, you or your attorney must file with the Court a written response, explaining your position at:2 United States Bankruptcy Court 211 West Fort Street, Suite 2100 Detroit, Michigan 48226 PLEASE TAKE FURTHER NOTICE THAT if you mail your response to the Court for filing, you must mail it early enough so the court will receive it on or before the date above. PLEASE TAKE FURTHER NOTICE THAT you must also serve the documents so that they are received on or before February 28, 2006 at 4:00 p.m. prevailing Eastern Time, in accordance with the Compensation Procedures Order, including to: Scott Shekell Deloitte Tax LLP 600 Renaissance Center, Suite 900 Detroit, Michigan 48243-1595

Response or answer must comply with Rule 8(b), (c) and (e) of the Federal Rules of Civil Procedure.

2
K&E 10964523.1

PLEASE TAKE FURTHER NOTICE THAT if no responses to the Application are timely filed and served, the Court may grant the Application and enter the order without a hearing as set forth in Rule 2016-3 of the Local Rules for the United States Bankruptcy Court for the Eastern District of Michigan. Dated: February 13, 2006 KIRKLAND & ELLIS LLP /s/ Ray C. Schrock Richard M. Cieri (NY RC 6062) Citigroup Center 153 East 53rd Street New York, New York 10022 Telephone: (212) 446-4800 Facsimile: (212) 446-4900 -andDavid L. Eaton (IL 3122303) Ray C. Schrock (IL 6257005) Marc J. Carmel (IL 6272032) 200 East Randolph Drive Chicago, Illinois 60601 Telephone: (312) 861-2000 Facsimile: (312) 861-2200 -andCARSON FISCHER, P.L.C. Joseph M. Fischer (P13452) 4111 West Andover Road West - Second Floor Bloomfield Hills, Michigan 48302 Telephone: (248) 644-4840 Facsimile: (248) 644-1832 Co-Counsel for the Debtors

3
K&E 10964523.1

CERTIFICATE OF SERVICE I, Ray Schrock, an attorney, certify that on the 13th day of February, 2006, I caused to be served, by e-mail, facsimile and by overnight delivery, in the manner and to the parties set forth on the attached service lists, a true and correct copy of the foregoing First Interim Fee Application of Deloitte Tax LLP as Tax Service Providers for the Debtors for Allowance of Interim Compensation for Service Rendered and Expenses Incurred from September 1, 2005 through December 31, 2005.

Dated: February 13, 2006 /s/ Ray C. Schrock Ray C. Schrock

K&E 10964710.1

Served via Electronic Mail

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In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

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Jim Cambio Of Ingersoll Joseph T. Deters

Service de la Tresorerie

treasReg@michigan.gov steve.e.spence@usdoj.gov laplante@millercanfield.com tpryce@ford.com jcambio@tax.ri.gov elantz@town.ingersoll.on.ca radom@butzel.com treasurer@tos.state.oh.us tsherick@honigman.com Frank.Chaffiotte@cit.com e-rental@ur.com msaintdenis@ville.farnham.qc.ca blanderson@eastman.com kandrews@e-bbk.com wdiehl@e-bbk.com bbyrne@e-bbk.com

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ADDRESS1 590 Madison Ave 100 Bloomfield Hills Pkwy Ste 100 400 Renaissance Center Sears Tower Ste 5800 425 Lexington Ave 211 W Fort St Ste 700 51 W 52nd St 1062 S 4th Ave PO Box 16253 7925 Kingsland Dr 1609 Biddle Ave 1 5 Notre Ave 2204 Walkley Rd PO Box 8040 576 West Pk Ave 576 West Pk Dr PO Box 9951 484 Middle Rd PO Box 818 200 South Main St 303 W Commonwealth Ave 711 Pennington Ave 201 N Figueroa St No 786 200 W Washington St 13th Fl PO Box 128 161 E Grand River 100 Mcmorran 201 N Second St 250 Stephenson Hwy DuPont Legal D 7156 4611 North 32nd St 1084 Doris Rd 47690 E Anchor Ct PO Box 105499 PO Box 890691 PO Box 740434 PO Box 640387 PO Box 642444 PO Box 60500 Attn Lease Administration Attn Lease Administration 7255 Crossleigh Court Ste 108 100 N Senate Ave PO Box 7218 PO Box 4660 PO Box 1803

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COUNTRY

Canada Canada

Director's Office for Taxpayer Services Division

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of the City of Montgomery

2120 West End Ave Ste 100 Nashville 3100 Smoketree Ct Ste 600 Raleigh Toledo Indianapolis Indianapolis Montgomery Grand Rapids

In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

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Canada Customs & Rev Agency Technology Ctr 875 Heron Rd 700 Leigh Capreol 11 Station St 700 Leigh Capreol Ottawa Technology Centre Midwest Regional Office 175 W Jackson Blvd Ste 90 Department Of Revenue Dept Of Commerce & Nat Res PO Box 30004 Matthew Rick Asst Attorney General PO Box 30754 State Of Michigan Mc Dept 77833 State Secondary Complex 7150 Harris Dr PO Box 30015 430 W Allegan St Jennifer Nelles First Plaza County Of Fresno Office of Child Support 24901 Northwestern Hwy 302 1985 Blvd Se PO Box 1192 21 Albert St 126 North Pearl St 1306 E Triumph Dr 356 Main St 115 West Church St 30 King St East PO Box 520 PO Box 67 315 North Main St 200 E Big Beaver PO Box 33525 7201 W Friendly Ave 12003 Toepher Rd

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ADDRESS2

CITY

STATE MI MI CT OH IL MI NC MI

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In re: Collins & Aikman Corp., et al. Case No. 05-55927 (SWR)

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EXHIBIT A

EXHIBIT B

EXHIBIT B

Deloitte Tax LLP Tax Service Providers and Tax Consultants to Collins & Aikman, Inc. et al., Debtors For the Period of September 1, 2005 through December 31, 2005 Sorted by Project and Professional for Tax Services

Name General corporate history CASSILL, REBECCA L FRIESTEDT, THEIA A HOFFMAN, DAVID N LYONS, CYNTHIA D SHEKELL, SCOTT L STARZYNSKI, STEVEN D TEGGART, MARK JOHN JR Bankruptcy plan details FRIESTEDT, THEIA A

Title

Service Line

Hourly Rate

Billable Hours

Total Fees

Senior Manager Partner Staff Partner Senior Staff Manager

TAX TAX TAX TAX TAX TAX TAX TAX

375 475 675 65 575 375 200 475

8.5 21.1 6.1 4.0 0.6 42.0 11.4 93.7 7.2 7.2 35.1 1.2 9.9 50.3 2.2 2.5 1.1 102.3 6.0 5.6 3.2 14.8 37.8 9.7 47.5 14.8 1.0 1.0 3.5 15.0 1.1 1.6 38.0 0.5 5.0 5.5 2.0 3.3 1.0 2.0 3.6 29.9 3.4 1.0 2.6 48.8 0.5 15.2 0.3 0.7 3.5 0.5 1.3 5.4 27.4 385.1

$3,188 $10,023 $4,118 $260 $345 $15,750 $2,280 $35,963 $3,421 $3,421 $8,600 $572 $5,445 $23,903 $1,485 $1,190 $743 $41,936 $1,620 $2,520 $644 $4,784 $5,292 $4,365 $9,657 $9,956 $675 $675 $1,575 $8,100 $397 $1,080 $22,458 $225 $2,700 $2,925 $950 $2,194 $675 $1,350 $1,710 $20,183 $1,935 $375 $1,755 $31,126 $33 $7,220 $16 $203 $866 $33 $85 $2,025 $10,479 $162,749

Internal Revenue Code Section 382 Limitation Analysis BRIDENSTINE, TRAVIS J Staff FRIESTEDT, THEIA A Manager Senior Manager GERSTEL, KENNETH A GUNDRUM, JENNIFER M Manager HOFFMAN, DAVID N Partner ROWE, LEONARD A II Manager Director ZIMET, LEE G International Assignment Services Consulting CATANA, TARA M Senior JORAH, CHRISTINE L Senior Manager MOMIN, JASMINE SULTANALI Staff Loan staff arrangement state and local tax consulting GUILLEN, JOHANNA TERESA Senior WRIGHT, CHARLES T Senior Manager Internal Revenue Service audit support BOOCOCK, STEPHEN W BOULET, WILLIAM P JR GANNON, JAMES M PEZZETTI, MICHAEL J SHEKELL, SCOTT L URBANIAK, JULIE JOHNSON WOERTZ, KEVIN DAVID

TAX TAX TAX TAX TAX TAX TAX TAX TAX TAX

245 475 550 475 675 475 675 270 450 200

TAX TAX

140 450

Director Director Partner Senior Manager Partner Senior Manager Partner

TAX TAX TAX TAX TAX TAX TAX

675 675 675 450 540 360 675

Assistance regarding Canadian Anti-abuse legislation PEZZETTI, MICHAEL J Senior Manager SHEKELL, SCOTT L Partner Internal and External planning meetings ATHANAS, JOHN A BOOCOCK, STEPHEN W CRYAN, THOMAS M DOUGHERTY, JAMES A FRIESTEDT, THEIA A HOFFMAN, DAVID N SHEKELL, SCOTT L STARZYNSKI, STEVEN D ZIMET, LEE G Chapter 11 administration BELL, RENEE ELISE FRIESTEDT, THEIA A KONSTANTINIDIS, ANDRIANA DONNA KROZEK, DEREK J NELSON, CARY KEN OLIVER, KRISTINE T PATTERSON, MARY ANN STARZYNSKI, STEVEN D

TAX TAX

450 540

Senior Manager Director Director Director Manager Partner Partner Senior Director

TAX TAX TAX TAX TAX TAX TAX TAX TAX

475 675 675 675 475 675 575 375 675

Staff Manager Staff Senior Staff Staff Staff Senior

TAX TAX TAX TAX TAX TAX TAX TAX

65 475 65 290 245 65 65 375

Total hours and amount sought

EXHIBIT C

EXHIBIT C

Statement by Deloitte Tax LLP Tax Service Providers and Tax Consultants to Collins & Aikman Corporation et al., Debtors For the Period of September 1, 2005 through December 31, 2005 Sorted by Day and Professional for Tax Services

Initials

Date

Description

Billable Time

Fixed Rate

Billable Fees

ATHANAS, JOHN A JAA 9/12/2005 Conference call with T. Cryan and J. Dougherty JAA 12/9/2005 Discussions with R. Norred regarding the data collection process JAA 12/28/2005 Data request discussions & setting up conference calls BELL, RENEE ELISE REB 12/12/2005 MD Assessments updated for 2006 BOOCOCK, STEPHEN W 12/3/2005 Printed documents re: Collins & Aikman IRS audit; printed opening conference checklist, met with S. Shekell to discuss Collins & Aikman IRS Audit, company and SWB conference call tomorrow 12/3/2005 Completed Power of Attorney form for Collins & Aikman, e-mail S. Shekell for employee identification number and confirmation of address, SWB review Collins & Aikman websire, IRS audit documents, mapquest driving directions, prepare outline for phone conversa 12/3/2005 Participated in conference call with G. White and R. Norred of Collins & Aikman to discuss their meeting with team coordinator and contingent liability company. Expert last SWB week re: TAW and CARMI transactions, provide my thoughts and recommendations, disc SWB 12/3/2005 Prepared summary of exam management services for Collins & Aikman, together with estimate of hours and E-mail to S. Shekell for review and commen SWB 12/3/2005 E-mailed summary of exam management engagement for Collins & Aikman to R. Norred and Gene for review and commen 12/3/2005 E-mailed response to G. White of Collins & Aikman re: offer to set up teleconference with B. Boulet to discuss audit of researach and development credit study and SWB response to G. White's status update email 12/3/2005 Reviewed e-mail from G. White; phone conversation with G. White, left voicemails for B. Boulet to try to arrange conference call on IRS audit of research and development SWB credit 12/3/2005 Met with G. White and R. Norred prior to IRS progress meeting; attend IRS progress meeting at Collins & Aikman, attend meeting with IRS team manager, team coordinator SWB and engineer to discuss approach to auditing research and development credit, discuss CA SWB 12/3/2005 E-mailed update on Collins & Aikman audit to S. Shekel SWB 12/3/2005 Attended Collins & Aikman opening conference 12/6/2005 E-mailed to R. Norred and G. White at Collins & Aikman with my observations, thoughts from last progress meeting and answer on whether appeals will take a case with no SWB tax deficiency BOULET, WILLIAM P JR WPB 12/3/2005 Participated in conference call with the client and Steve Boocock regarding IRS sampling methodology and related issues pertaining to the research credi BRIDENSTINE, TRAVIS J TJB 11/30/2005 Researching Products' issuance of preferred stock to Textron and its impact on 382 study, discussions with Jennifer Gundrum TJB 11/30/2005 Inputing numbers into initial 382 calculation TJB 12/1/2005 382 analysis and discussions with Jennifer Gundrum TJB 12/8/2005 Verifying assumptions for initial 382 analysis, research regarding the formation of separate public groups for each sale of shares by 5% shareholders TJB 12/9/2005 382 analysis, adding testing dates to 382 analysis TJB 12/12/2005 Adding 13D & G information to 382 study/applying small and cash issuance exception to certain testing dates, meetings TJB 12/13/2005 Applying small and cash issuance exception to 382 analysis/verifying input in 382 analysis, meetings TJB 12/14/2005 Revising 382 analysis TJB 12/14/2005 Filing public documents for 382 analysis, discuss with Ken Gerste TJB 12/15/2005 Revising 382 analysis TJB 12/16/2005 Filing public information for 382 analysis TJB 12/21/2005 Meeting with Jennifer Gundrum about outline and call with Lee Zime CASSILL, REBECCA L 11/2/2005 Review information from KCCLLC website to pull the appropriate bankruptcy filings; information included monthly operating reports, first day motions, first day orders, etc. RLC 11/3/2005 Finish pulling bankruptcy filings; review and put together summary document; talk with Cynthia Lyons on presentation in notebooks; meet with Hoffman on open items RLC

1.0 0.5 0.5 2.0 0.5 0.5 1.3 3.8 0.8 1.0 0.2 0.3 0.3 6.3 0.3 3.3 0.8 18.0 1.0 1.0 2.3 1.8 4.3 0.3 0.4 10.0 6.9 4.0 2.0 0.7 0.7 1.7 35.1 5.0 3.5 8.5

475 475 475

$475 $239 $238 $951 $33 $33 $844 $2,531 $506 $675 $116 $169 $169 $4,219 $223 $2,194 $506 $12,151

65

675 675 675 675 675 675 675 675 675 675 675

675

$675 $675 $564 $441 $1,054 $77 $98 $2,450 $1,691 $980 $490 $172 $172 $417 $8,603 $1,875 $1,313 $3,188

245 245 245 245 245 245 245 245 245 245 245 245

375 375

EXHIBIT C

CATANA, TARA M TMC 12/24/2005 reviewed the october and november compensation for the international assigness TMC 12/24/2005 contacted C&A for the wire transfer amounts due TMC 12/24/2005 collected payroll data from assignees and foreign offices in order to work on the year end payro CRYAN, THOMAS M TMC 9/12/2005 Discussion with J. Dougherty and J. Athanas DOUGHERTY, JAMES A JAD 9/12/2005 Collins Aikman discussions JAD 9/12/2005 Discussion with T. Cryan and J. Athanas FRIESTEDT, THEIA A TAF 10/5/2005 Meet with Hoffman to discuss C&A TAF 10/11/2005 Search for public filings, begun to print latest SEC documents and discussion with D. Hoffman TAF 10/13/2005 Discuss court documents with Hoffman TAF 10/24/2005 Prepared preliminary budget and high-level description of first 3 mo of projec TAF 10/25/2005 Visited company's website, looked for bankruptcy filings. Went to advisor's website and browsed Chapter 11 docs posted. Printed relevant documents TAF 10/25/2005 Searched latest SEC filing for relevant docs/printed relevant docs found TAF 10/25/2005 Made adjustments to budget, call with Ken Gerstel to discuss budget for "change in ownership" projec 10/26/2005 Read 10K and 10Q for background, items of tax relevance (1.4 hour). Identified prior restructurings/acquisitions (1.2 hours). Searched bankruptcy filings (.9 hours). Discuss TAF with Hoffman (.5 hours) TAF 10/28/2005 Next steps (pulling bankruptcy documents) and worked on to dos, including workplan and data reques TAF 11/7/2005 Correspondence to/from B. Cassill regarding bankruptcy documents she printed from public available information/meet with Hoffman TAF 11/10/2005 Read court filings TAF 11/10/2005 Organized binders of SEC and court filings to be distributed to Deloitte team TAF 11/11/2005 E-mails regarding kick-off meeting TAF 11/11/2005 Prepared agenda for kick-off meeting TAF 11/11/2005 Began working on preparing detailed workplan TAF 11/14/2005 Discussion with Starzynski regarding the project and history of acquisitions/dispositions, and other transactions C&A went through TAF 11/14/2005 Conference call with other Deloitte Tax team to prepare for conf call with client on 11/16 TAF 11/14/2005 Prepared working group list and summary workplan TAF 11/15/2005 Finalized detailed workplan, sent e-mail to Deloitte team to gather input/review TAF 11/16/2005 Worked on the agenda for 11/17 conference call with the client TAF 11/16/2005 Read e-mails; discussions with Starzynski and Hoffman TAF 11/16/2005 Worked on data request TAF 11/16/2005 Call with Deloitte team TAF 11/17/2005 Examined Section 382 limitation/RBIG study performed for 2001 change in ownership TAF 11/17/2005 Worked on data request TAF 11/17/2005 Reviewed 10-K analysis prepared by Starzynski; proposed changes/edits TAF 11/18/2005 Edited data request to reflect comments from Hoffman, Chapman, and Gerstel TAF 11/18/2005 Discussed preparation of summary of bankruptcy filings with Starzynski/ gathered additional info to be included in filings binde TAF 11/18/2005 Bankruptcy technical updates/study, discussions w/ Hoffman TAF 11/29/2005 Updated working group list with additional information received; distributed internally TAF 11/29/2005 Reviewed summary of court filings prepared by Starzynski; reviewed summary of press reselases prepared by Starzynsk TAF 11/30/2005 Read press releases, discussed with Starzynski changes to be made to summary of bankruptcy and public filings TAF 12/2/2005 Assisted Starzynski on how to access bankruptcy filings TAF 12/9/2005 E-mail to Starzynski re: updates, call with Hoffman re: update TAF 12/12/2005 Call with Scott Shekell and Hoffman. Call Gerstel re: 382 ownership change study TAF 12/13/2005 Read bankruptcy documents TAF 12/13/2005 Met with Starzynski to discuss search/update for new bankruptcy filings TAF 12/19/2005 Time report TAF 12/19/2005 Read new bankruptcy filings from Starzynski's court filings research TAF 12/19/2005 Began to work on detailed workplan, discuss with Hoffman TAF 12/19/2005 Made final edits to summaries TAF 12/19/2005 Discussed with Starzynski information received (income tax return filings) TAF 12/19/2005 Began working on model TAF 12/20/2005 Verified tax returns received and looked for net operating loss schedules. exchanged e-mails with Ken Gerstel (San Diego) regarding NOLs TAF 12/21/2005 Read binders with court filings GANNON, JAMES M

1.0 0.5 4.5 6.0 1.0 1.0 1.0 1.0 2.0 0.5 1.0 0.5 1.5 2.0 1.0 1.0 4.0 1.0 1.0 3.4 1.7 0.6 1.8 1.5 1.5 0.5 2.8 0.4 0.5 0.8 2.2 0.8 1.2 0.7 1.3 1.1 0.9 1.1 0.5 0.8 1.0 0.3 0.2 0.6 1.0 0.3 0.1 1.6 0.8 0.1 0.3 0.5 1.2 0.7 48.3

270 270 270

$270 $135 $1,215 $1,620 $675 $675 $675 $675 $1,350 $238 $475 $238 $713 $950 $475 $475 $1,900 $475 $475 $1,615 $808 $285 $855 $713 $713 $238 $1,330 $190 $238 $380 $1,045 $380 $570 $333 $618 $523 $428 $523 $238 $380 $475 $143 $95 $285 $475 $153 $48 $760 $380 $48 $143 $238 $570 $333 $22,953

675

675 675

475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475

EXHIBIT C

JMG

7/15/2005 Consulting re: Sec. 952(c) recapture

1.0 1.0 2.5 1.5 1.0 1.0 0.9 3.0 9.9 0.3 0.4 0.5 0.3 1.0 0.5 1.0 1.3 0.8 0.2 0.5 0.7 1.0 0.5 0.5 0.3 1.7 0.5 1.0 0.5 0.5 0.4 0.1 0.5 0.3 0.8 0.7 0.4 0.4 0.3 0.1 0.8 1.3 0.5 0.4 0.3 0.5 0.2 0.2 0.8 1.0 0.8 0.8 0.8 1.0 0.4 0.5 0.5 1.5 0.4

675

$675 $675 $1,375 $825 $550 $550 $495 $1,650 $5,445 $42 $56 $70 $42 $140 $70 $140 $182 $105 $28 $70 $98 $140 $70 $70 $42 $238 $70 $140 $70 $70 $56 $14 $70 $35 $105 $98 $56 $56 $35 $14 $112 $182 $70 $56 $42 $70 $28 $28 $112 $140 $112 $112 $112 $140 $56 $70 $70 $210 $56

GERSTEL, KENNETH A KAG 11/28/2005 Section 382 consultations, review history with Jennifer Gundrum, consider tech issues, issuance of sub stock, etc KAG 12/13/2005 Calls & consultation re: 382 analysis KAG 12/14/2005 382 consults with Travis Bridenstine, etc. KAG 12/16/2005 382 consults KAG 12/20/2005 382 consults re prior study, correspondence with Friestedt KAG 12/22/2005 Section 382 positions write up & consults with Zimet and Gundrum GUILLEN, JOHANNA TERESA JTG 12/17/2005 Created file for Collins & Aikman Products containing Sales and Use Tax audit correspondence from audito JTG 12/17/2005 Created file for Collins & Aikman Products containing Single Business Tax audit correspondence from audito JTG 12/17/2005 Created list of information requested by auditor for Collins & Aikman Automotive Exterio JTG 12/17/2005 Called to Stricklin Owens, auditor of Collins & Aikman Products, to discuss current status of information request and additional information required JTG 12/17/2005 Gathered copies of all the information requested by the Michigan auditor for Collins & Aikman Automotive Exteriors and organize it in a binde JTG 12/17/2005 Drove to and from Collins & Aikman in Troy, Michigan JTG 12/17/2005 Gathered copies of all the information requested by the Michigan auditor for Collins & Aikman Automotive Interiors and organized in a binde JTG 12/17/2005 Gathered copies of all the information requested by the Michigan auditor for Collins & Aikman Products and organized it in a binde JTG 12/17/2005 Created list of information requested by auditor for Collins & Aikman Products JTG 12/17/2005 Created file for Colllins & Aikman Automotive Interiors containing all the correspondence received from autdito JTG 12/17/2005 Created file for Collins & Aikman Automotive Interiors containing all the auditor correspondence received JTG 12/17/2005 Created list of information requested by auditor for Collins & Aikman Automotive Interio JTG 12/17/2005 Met with J. Heckman and R. Norred to review notices received and separate them to the corresponding entity JTG 12/17/2005 Met with J. Heckman, R. Norred, and C. Wright to discuss responsibilities of engagement JTG 12/17/2005 Drove to and from Collins & Aikman in Troy, Michigan JTG 12/17/2005 Prepared list of exemption certificate numbers found for Collins & Aikman JTG 12/17/2005 Searched through Collins & Aikman files for sales and use tax exemption certificates to respond to request from suppliers JTG 12/17/2005 Searched for 2004 payment information for JPS Automotive in Missouri to compare against adjustment provided by state on notice JTG 12/17/2005 Searched for 2004 payment information for Collins & Aikman Automotive Interiors in Missouri to compare against adjustment provided by state on notice JTG 12/17/2005 Wrote note to file stating that Missouri record of payments for JPS Automotive agrees with internal records JTG 12/17/2005 Wrote letter to Missouri requesting detail for their payment records of Collins & Aikman Automotive Interiors to resolve discrepancy with internal records JTG 12/17/2005 Prepared sample email for J. Heckman to send to controllers requesting a copy of all Sales & Use Tax exemption certificates JTG 12/17/2005 Met with J. Heckman to discuss progress of notices and giver her notices completed for review JTG 12/17/2005 Wrote cover letter and complete check request form to pay tax due in Arkanas for Wickes Asset Management, Inc JTG 12/17/2005 Called city of Bowling Green Kentucky to request information about requirements to restore Collins & Aikman Automotive Interiors to good standin JTG 12/17/2005 Wrote letter to North Carolina requesting that original refund check issued to Collins & Aikman Fabrics be cancelled and for them to issue a new chec JTG 12/17/2005 Met with J. Heckman and R. Norred to assign notices and discuss procedure for responding to notices JTG 12/17/2005 Added 2003 federal and Single Business Tax return to Collins & Aikman Products binde JTG 12/17/2005 Added 2003 federal and Single Business Tax return to Collins & Aikman Automotive Interiors binde JTG 12/17/2005 Added 2003 federal and Single Business Tax return to Collins & Aikman Automotive Exteriors binde JTG 12/17/2005 Called Plastech Engineered Products, Inc. re: notice requesting W-9 form JTG 12/17/2005 Wrote letter to Massachussets in response to notice to Collins & Aikman Fabrics JTG 12/17/2005 Prepared schedule listing liabilities calculated when 2004 return was prepared and how each was handled and paid versus note of bankruptcy sen JTG 12/17/2005 Drove to and from Collins & Aikman in Troy, Michigan JTG 12/17/2005 Put together package of additional information requested by auditor for Collins & Aikman Automotive Interiors JTG 12/17/2005 Put together package of additional information requested by auditor for Collins & Aikman Automotive Exteriors JTG 12/17/2005 Prepared W-9 form requested by Club Car, Inc for JPS Automotive JTG 12/24/2005 Made corrections to Missouri Collins & Aikman Automotive Interior notice response letter JTG 12/24/2005 Made corrections to Massachusetts Collins & Aikman Fabrics notice response letter JTG 12/24/2005 Prepared a schedule containing all the tax liabilities and return payments made for the 2004 returns JTG 12/24/2005 Wrote letter to Arkansas in response to notice received for Wickes Asset Management JTG 12/24/2005 Prepared form required by Kentucky to re-establish Collins & Aikman Automotive Interiors into good standing JTG 12/24/2005 Reviewed incoming sales tax exemption certificates and organize in binder JTG 12/24/2005 Called the state of Kentucky to inquire about the requirements to re-establish Collins & Aikman Automotive Interiors into good standing JTG 12/24/2005 Verified payment information per state notice with payment records for JPS Automotive in Missour JTG 12/24/2005 Searched for form and information required by Kentucky to re-establish Collins & Aikman Automotive Interiors into good standing JTG 12/24/2005 Called Plastech to verify for which subsidiary they are requesting a W-9 form JTG 12/24/2005 Drove to and from Collins & Aikman in Troy, Michigan JTG 12/24/2005 Wrote penalty waiver request letter to IRS for notice received by Collins & Aikman Automotive JTG 12/24/2005 Wrote letter to Arkansas in response to notice received for Wickes Asset Management

550 550 550 550 550 550

140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140 140

EXHIBIT C

JTG JTG JTG JTG JTG JTG

12/24/2005 Reviewed payment information with additional data received from accounts payable departmen 12/24/2005 Prepared state tax cash payment tracking schedule 12/24/2005 Wrote penalty waiver request letter to IRS for notice received by Collins & Aikman Automotive 12/24/2005 Wrote letter to Mississippi in response to notice received for Wickes Asset Management 12/24/2005 Wrote penalty waiver request letter to IRS for notice received by Mobis, LLC 12/24/2005 Drove to and from Collins & Aikman in Troy, Michigan

0.8 3.5 1.0 0.5 1.0 0.5 37.8 3.1 1.3 4.7 3.0 2.5 1.3 1.3 2.8 0.5 0.7 0.4 0.2 0.6 0.2 1.5 3.4 3.6 1.5 0.7 0.3 0.5 2.5 2.0 1.5 1.5 0.5 0.5 2.0 3.0 1.2 1.5 50.3

140 140 140 140 140 140

$112 $490 $140 $70 $140 $70 $5,292 $1,473 $618 $2,233 $1,425 $1,188 $618 $618 $1,330 $238 $333 $190 $95 $285 $95 $713 $1,615 $1,710 $713 $333 $152 $238 $1,188 $950 $713 $713 $238 $238 $950 $1,425 $570 $713 $23,902

GUNDRUM, JENNIFER M JMG 9/21/2005 C&A data retrieval for 382 study JMG 9/23/2005 Print out 13g and annual reports for C&A JMG 9/26/2005 Preliminary review of SEC filings JMG 9/27/2005 Preliminary review of SEC filings and summarizing information JMG 9/28/2005 Preliminary review of SEC filings and summarizing information JMG 11/14/2005 Review preliminary findings JMG 11/16/2005 Research on preferred stock and losses JMG 11/17/2005 Review of SEC filings and prior 382 workpapers and prepare information reques JMG 11/28/2005 Discuss planning/process of 382 analysis with Gerstel JMG 11/28/2005 Review SEC filings for 382 analsysis JMG 11/29/2005 Discuss 382 template with Leonard Rowe JMG 11/30/2005 Discuss information and 382 model with Travis Bridenstine JMG 11/30/2005 Discuss findings on inclusion of sub stock in analysis JMG 12/1/2005 Discuss spreadsheet analysis with Travis Bridenstine JMG 12/2/2005 Review 8K for preferred stock issuance; review regs. on separate and parent attribute testing JMG 12/3/2005 Review initial analysis spreadhsheet to determine risk areas for ownership JMG 12/3/2005 Review 13gs and 13ds JMG 12/7/2005 Review and adjust spreadsheets; discuss with team JMG 12/11/2005 Further review of preferred stock rules, meeting JMG 12/12/2005 Discuss necessary changes with Travis Bridenstine and team JMG 12/13/2005 Discuss issues with Ken Gerstel and Travis Bridenstine JMG 12/16/2005 Review Travis Bridenstine's updates to spreadsheets and make corrections JMG 12/17/2005 Update spreadsheets JMG 12/18/2005 Review spreadsheet and 10-K JMG 12/18/2005 Review of spreadsheets and 10-K analysis JMG 12/19/2005 Review 382 spreadsheets JMG 12/20/2005 Analysis of prior NOLs JMG 12/21/2005 Meeting with Travis Bridenstine about spreadsheets and outstanding issues JMG 12/21/2005 Outlining outstanding issues and looking into additional issues JMG 12/22/2005 Conference call with Ken Gerstel and Lee Zimet to discuss 382 JMG 12/22/2005 Outline open items and research outstanding issues in preparation for cal

475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475 475

HOFFMAN, DAVID N DNF 9/1/2005 Evaluate next steps, including workplan preparation and K&E meeting DNF 9/6/2005 Correspondence with Shekell and Womak regarding C&A conflicts and engagement matters DNF 9/7/2005 C&A draft engagment letter review and correspondence DNF 9/7/2005 Discuss C&A staffing approach with Kushner DNF 9/8/2005 Additional C&A engagement letter correspondence DNF 9/9/2005 Study C&A case developments from TCR DNF 9/12/2005 Call with Zimet re conflict check and engagement status DNF 9/13/2005 Review conflict check email and related correspondence DNF 9/19/2005 Track acquisition and case developments DNF 9/22/2005 Call with Shekell re engagement progress and correspondence with the C&A team re same DNF 10/5/2005 Meet with Friestedt to plan engagement DNF 10/10/2005 Follow C&A case developments and look at timeline DNF 10/11/2005 Discuss first steps, important court documents with Friestedt DNF 10/13/2005 Discuss specific court documents w/ Friestedt DNF 10/17/2005 Meeting correspondence and planning DNF 10/24/2005 Preparation of 1st 3 month service and fee projections DNF 10/26/2005 Correspondence with Friestedt regarding bankruptcy filings DNF 10/28/2005 Follow C&A case developments and consider tax implications DNF 11/1/2005 Call w/ Maynes at Kirkland re case developments

0.5 0.5 1.2 0.5 0.5 1.1 0.7 0.4 0.5 0.6 0.5 1.1 0.5 0.5 0.5 0.9 0.5 0.6 0.3

675 675 675 675 675 675 675 675 675 675 675 675 675 675 675 675 675 675 675

$338 $338 $810 $338 $338 $743 $473 $270 $338 $405 $338 $743 $338 $338 $338 $608 $338 $405 $203

EXHIBIT C

DNF DNF DNF DNF DNF DNF DNF DNF DNF DNF DNF DNF DNF DNF DNF DNF DNF DNF DNF DNF DNF

11/2/2005 Call with Shekell re kick-off meeting 11/2/2005 Track case developments 11/3/2005 Background filings review, including meeting with Cassi 11/7/2005 Meet w/ Friestedt re C&A engagement issues 11/11/2005 Preparation for next week kick-off including agenda discussions w/ Friestedt and related coordination 11/14/2005 Preparation for kick-off call w/ client, including agenda, workplan, working group lis 11/14/2005 Calls w/ team for meeting preparation; 11/15/2005 Study case news 11/16/2005 Kick-off call with the client and related preparation and follow-up 11/16/2005 Data request and workplan considerations 11/17/2005 Work with Friestedt on data request and related planning 11/18/2005 Revise and send full tax data request and related coordination 11/28/2005 Discussion w/ Friestedt regarding data timing 11/29/2005 Follow international sale implications 11/29/2005 Tax data gathering and related 12/1/2005 Follow C&A developments, engagement documentation 12/1/2005 Call w/ Maynes at K&E re 382 study 12/2/2005 382 study analysis and correspondence 12/5/2005 Correspondence with Shekell and team regarding C&A data and issues 12/12/2005 Preparation and discussions w/ Friestedt and Shekell re tax issues 12/19/2005 Evaluate tax return data received and plan with Friestedt and Starzynski regarding modeling of same

0.3 0.5 1.0 0.5 1.5 4.2 1.5 0.5 3.3 1.0 2.5 2.5 0.4 0.5 1.4 1.0 0.4 0.8 0.9 0.6 1.0 38.2 0.1 0.2 0.2 1.2 0.3 0.3 0.2 0.1 3.0 5.6 0.3 0.3 0.7 0.7 4.0 4.0 0.1 0.4 2.5 0.2 3.2 3.5 3.5 0.5 0.5 0.4 0.5 0.4 1.3

675 675 675 675 675 675 675 675 675 675 675 675 675 675 675 675 675 675 675 675 675

$203 $338 $675 $338 $1,013 $2,848 $1,013 $338 $2,228 $675 $1,688 $1,688 $270 $338 $945 $675 $270 $540 $608 $405 $675 $25,798 $45 $90 $90 $540 $135 $135 $90 $45 $1,350 $2,520 $16 $16 $203 $203 $260 $260 $24 $80 $500 $40 $644 $858 $858 $33 $33 $26 $33 $26 $85

JORAH, CHRISTINE L CLJ 12/17/2005 Review notes from meeting & leave message re: Dec. 20th due date CLJ 12/17/2005 Discuss tax codes needed for payroll reporting with Tara Catana CLJ 12/17/2005 Telephone Debra Johnson re: payroll codes CLJ 12/17/2005 Review current paycodes and recommend new for inter'l payrol CLJ 12/17/2005 Revise payroll codes, discuss with Tara and email to Debra Johnson CLJ 12/17/2005 Phone call with Debra Johnson re: how to report tax equalization paymen CLJ 12/17/2005 Answer email from Japanese office re: 2005 authorization list and email to Debra Johnson regarding same CLJ 12/17/2005 Review notes from Amy Lesh re: outstanding info for Tim Faenger's return CLJ 12/31/2005 Use GA Tracker to look up assignee information and build 2005 authorization lis KONSTANTINIDIS, ANDRIANA DONNA ADK 11/18/2005 Chapter 11 Administration KROZEK, DEREK J DJK 12/7/2005 Drafted billing Email LYONS, CYNTHIA D CDL 11/3/2005 Chapter 11 Administration MOMIN, JASMINE SULTANALI JSM 12/10/2005 Discuss 2003 returns with C. Jorah, send email to K. Bond for 2003 returns JSM 12/10/2005 E-mail correspondence to K. Bond for copy of 2003 returns and compared to the versions previously sen JSM 12/10/2005 Finalized any open items re: the return and printed off communication for the file JSM 12/10/2005 Finalized edits to the returns and singed into tax processing NELSON, CARY KEN CKN 12/5/2005 Printing out SEC filing reports, 10k, 10Q, annual reports, notes, etc OLIVER, KRISTINE T KTO 12/15/2005 Box and UPS 9 binders to Chicago office for D. Krozek PATTERSON, MARY ANN MAP 10/14/2005 Internal bookkeeping MAP 10/14/2005 Internal bookkeeping MAP 10/14/2005 Internal bookkeeping PEZZETTI, MICHAEL J

450 450 450 450 450 450 450 450 450

65

290

65

200 200 200 200

245

65

65 65 65

EXHIBIT C

MJP MJP MJP MJP MJP MJP

10/17/2005 Subpart F Issue for Textron deal 10/18/2005 Textron subpart F write-up and email to Gannon 10/21/2005 Finalize discussions and email to R. Norred 10/24/2005 Conference call with Textron to discuss audit valuation Subpart F 11/1/2005 C&A Call regarding Canadian CRA 12/8/2005 Discussion re: subpart F at Textron

1.0 1.0 0.5 0.5 0.5 0.5 4.0 2.0 0.5 2.5 1.5 1.0 2.5 2.5 1.5 0.5 1.5 3.0 1.0 1.5 0.5 0.5 1.0 1.5 1.0 21.0 0.5 1.0 0.6 0.3 0.6 3.0 1.5 7.0 1.5 2.0 1.0 4.5 5.0 1.1 0.5 4.0 2.5 1.0 2.0 2.5 0.3 3.0 2.0 4.0 3.0 48.4 5.5

450 450 450 450 450 450

$450 $450 $225 $225 $225 $225 $1,800 $950 $238 $1,188 $810 $540 $1,350 $1,350 $810 $270 $810 $1,620 $540 $810 $270 $270 $540 $810 $540 $11,340 $288 $575 $345 $174 $345 $1,726 $563 $2,625 $563 $750 $375 $1,688 $1,875 $417 $188 $1,500 $938 $375 $750 $938 $113 $1,125 $750 $1,500 $1,125 $18,154 $1,100

ROWE, LEONARD A II LAR 12/12/2005 382 consultations with team on various change calculation issues LAR 12/13/2005 Various 382 questions SHEKELL, SCOTT L 10/17/2005 Call with Textron then followup with R. Norred SLS 10/18/2005 Textron call and review of documents 5471 etc SLS 10/19/2005 Textron IRS audit discussion, subpart F and agreement review and discussion to prepare for IRS meeting SLS 10/20/2005 Prepare for and attend opening meeting with the IRS SLS 10/21/2005 Textron Information review and discuss with M. Pezzetti and R. Norred SLS 10/24/2005 Call with M. Pezzetti, T. Trenary, R. Norred on Textron indemnity SLS 10/31/2005 Assistance regarding Canadian Anti Abuse Legislation (Garr issues) SLS 11/1/2005 Assistance regarding Canadian Anti Abuse Legislation (Garr issues) SLS 11/29/2005 Analysis regarding Textron SLS 12/1/2005 Reviewed Textron information SLS 12/6/2005 Analysis regarding Textron SLS 12/7/2005 Assistance regarding Canadian Anti Abuse Legislation (Garr issues) SLS 12/8/2005 Textron issue and call with J. Heckmen of Collins & Aikman SLS 12/14/2005 Phone call with J. Heckman on Textron, prop taxes etc. and follow up on these items. Also wirtte up on textron issue SLS 12/20/2005 Bankruptcy planning discussions, coordination, etc. SLS SLS SLS SLS SLS SLS 11/14/2005 Reviewed agenda for kickoff call 11/16/2005 Conference call regarding kick off 9/22/2005 Call with D. Hoffman re: progress 11/2/2005 Call with D. Hoffman re: kick off 12/12/2005 Discussion with D. Hoffman

475 475

540 540 540 540 540 540 540 540 540 540 540 540 540 540 540 575 575 575 575 575

STARZYNSKI, STEVEN D STS 11/14/2005 Discuss C&A overview with Friestedt and Hoffman, Review of companies SEC filings to gain better understanding of stock basis due to acquisitions and re-orgs, prepare memo of significant transactions STS 11/15/2005 Pull company filings, read through filings dating back to 1995, Review of companies SEC filings to gain better understanding of stock basis due to acquisitions and re-orgs, prepare memo of significant transactions, note year, type of acquisition & amoun STS 11/16/2005 Review of companys' SEC filings to gain better understanding of stock basis due to acquisitions and re-orgs, prepare memo of significant transactions STS 11/16/2005 Create tax bankruptcy data request for C&A, discuss with Friestedt items that we may need STS 11/16/2005 Kick off call with C&A, introductions, game plan for tax bankruptcy work STS 11/17/2005 Discussion with Friestedt regarding bankruptcy cases, summarize bankruptcy filings, help out on workplan and data reques STS 11/18/2005 Read through and summarize recent bankruptcy filings, read through and prepare summary of important press releases as they may impact the structure of the company STS STS STS STS STS STS STS STS STS STS STS STS 11/18/2005 Discussion with T. Friestedt re: bankruptcy filings 11/29/2005 Look through bankruptcy filings looking for anything that could be important in our tax bankruptcy modeling 11/30/2005 Pull and read latest press releases, update our press release summary, changes to bankruptcy filings summary, discussions with Friested 12/2/2005 Bankruptcy filings 12/6/2005 Look up latest bankruptcy filings 12/7/2005 Update schedules for latest press releases and potential impact on our tax bankruptcy modeling 12/13/2005 Review C&A online bankruptcy filings, save to network, discuss with Friestedt 12/13/2005 Met with T. Friestedt re: bankruptcy filings 12/14/2005 Read through online bankruptcy court filings looking for anything that may impact our modeling and/or tax basi 12/15/2005 Administration, filing 12/19/2005 Create binders for C&A, update summaries for latest court filings and press releases, look through boxes of tax returns for important information, discussions with Friestedt and Hoffman 12/20/2005 Finish creating binders for C&A, look through returns for NOL information

375 375 375 375 375 375 375 375 375 375 375 375 375 375 375 375 375 375 375

TEGGART, MARK JOHN JR MJT 12/12/2005 Data collection for tax years 1999, 2000, 2001, 2002, and 2003

200

EXHIBIT C

MJT MJT

12/13/2005 Data collection for 2004 tax year. 12/14/2005 Data collection for tax years 1999 - 2004

2.3 3.6 11.4 1.1 1.1 1.0 0.6 1.6 4.0 1.0 1.0 0.6 0.7 1.1 1.3 9.7 0.7 1.0 0.9 1.1 3.7 385.1

200 200

$460 $716 $2,276 $396 $396 $675 $405 $1,080 $1,800 $450 $450 $270 $315 $495 $585 $4,365 $474 $675 $608 $743 $2,499 $162,749

URBANIAK, JULIE JOHNSON JJU 10/14/2005 C&A Textron meeting prepartion with R. Norred WOERTZ, KEVIN DAVID KDW 11/13/2005 Consulting re: IRS issues with S. Boocock KDW 11/13/2005 Consulting re: IRS issues with S. Boocock WRIGHT, CHARLES T CTW 10/5/2005 Met with T, Trenary, R. Norred; travel; fax and calls re: property taxes CTW 10/7/2005 Met with R. Norred; Participated in calls and e-mails re: property taxes with S. Aston CTW 10/10/2005 Called R. Norred; Participated in e-mails and calls re: Westland property taxes with S. Aston CTW 11/1/2005 Called R, Norred and S. Shekell re: Multistate assistance and staffing CTW 11/7/2005 Called R. Norred re: loan staff, consulting staff and messages to S. Shekel CTW 11/10/2005 Called re: loan staff and draft addendum; Meeting M. Faulkner re: terms CTW 12/17/2005 Met with J. Heckman and R. Norred re: loan staff duties and status of MI audits ZIMET, LEE G LGZ 9/12/2005 Call with D. Hoffman LGZ 11/14/2005 TC w/ Hoffman re; prep for client call LGZ 11/16/2005 TC w/ Jennifer Heckman re: kick-off meeting LGZ 12/22/2005 Conference call with J. Gundrum and K. Gerstel

360

675 675

450 450 450 450 450 450 450

675 675 675 675

Total hours and amount sought

EXHIBIT D

M&A TRANSACTION SERVICES

David N. Hoffman Partner Deloitte Tax LLP Chicago Office Tel: 312-486-2283 Email: dhoffman@deloitte.com In his role in the M&A Transaction Services Group, David specializes in delivering tax consultative services relating to mergers and acquisitions, and other significant capital transactions such as restructurings, dispositions, and debt work-outs. He has worked with many of Deloittes most prominent strategic and private equity clients, leading due diligence, structuring, and other tax planning for domestic and international transactions. A significant portion of Davids practice involves working with financially troubled or bankrupt entities, addressing complex tax issues and helping them reorganize in a tax-efficient manner. In connection with his work, David has developed expertise in maximizing the value of tax attributes such as net operating losses and tax basis, designing and implementing tax-advantaged acquisition and financing structures, and minimizing effective tax rates. David has advised in a wide variety of industries, including retail and distribution, manufacturing, aviation, health care, consulting, and energy. He is a frequent lecturer and instructor on M&A and other corporate tax matters. Representative reorganization clients:

United Airlines Tower Automotive Northwest Airlines Coram Healthcares Equity Committee AmeriKing

Collins & Aikman McLeod USA Cooker Restaurant Corporation Various privately held companies USG Corporation

David earned his J.D. degree from the University of Baltimore School of Law and his B.S. in Business Administration from the University of Richmond. He is a member of the AICPA and the American, Maryland, and Chicago Bar Associations. David currently serves on the Board of Directors of the Family Network, Inc. in Highland Park, Illinois.

Name: Scott L. Shekell Title: Partner Lead Tax Services Location: Detroit Tel: (313) 396 3297 Fax: (313) 392 7794 Email: sshekell@deloitte.com

Relevant Experience
Scott is a Partner in our Lead Tax Service Group. Scott has over fourteen years of experience including three years of auditing. Scott serves several US based multi-national companies including General Motors Corporation, ArvinMeritor, Inc., Compuware Corporation, Metaldyne, Inc. and Collins & Aikman Corporation. Scotts role on these engagements includes global coordination and delivery of all tax services. His direct experience in tax includes consultation and advice on a wide range of issues including: Tax accounting (SFAS 109); Mergers & acquisitions; Accounting methods; and Tax due diligence

Education/Professional affiliations
Scott received a bachelors degree from Walsh College with a major in accounting. He received a Masters in Business Administration from the University of Chicago with concentrations in accounting, finance and economics. He is a Certified Public Accountant in the State of Michigan and a member of the AICPA and MACPA.

Industry Experience
Automotive Manufacturing Software

EXHIBIT E

EXHIBIT E

Deloitte Tax LLP Tax Service Providers and Tax Consultants to Collins & Aikman Corporation et al., Debtors For the Period of September 1, 2005 to December 31, 2005 Expenses

Category Airfare

Date

Amount

Person

Description

$ $ Lodging $ $ Meals and Incidentals 11/28/2005 $ 11/28/2005 $ 12/13/2005 $ $ Transportation

56 HOFFMAN, DAVID N 10 HOFFMAN, DAVID N 12 BRIDENSTINE, TRAVIS J 78 Business Meals - Lunch at Pazzos with Friestedt and Starzynski to discuss C&A engagement planning Meals-Overtime Meals-Overtime

12/13/2005 $ 3 TEGGART, MARK JOHN JR Mileage charged for trip to C&A 12/13/2005 $ 6 TEGGART, MARK JOHN JR Mileage charged for trip to C&A $ 9 Miscellaneous - Courier, Postage, Telephone, Parking - out of town travel) 11/28/2005 $ 40 N/A Postage/Cour/Freight 12/17/2005 $ 11 N/A Postage/Cour/Freight 11/12/2005 $ 198 LYONS, CYNTHIA D Printing & Copying 12/7/2005 $ 263 LYONS, CYNTHIA D Printing & Copying 11/28/2005 $ 13 HOFFMAN, DAVID N Cellular Phone 12/12/2005 $ 3 HOFFMAN, DAVID N Teleconferencing - Call w/ Friestedt, Shekell, and Starzynski 12/21/2005 $ 12 FRIESTEDT, THEIA A Cellular Phone 12/31/2005 $ 106 STARZYNSKI, STEVEN D Pacer Quarterly Statement - Cost of printing off court documents from the Michigan Eastern Bankruptcy Court $ 645 $ 732 Total expenses and amount sought