My interpretation is that they will distribute what they can...

My interpretation is that they will distribute what they can initially which is $5-$7.5m but will keep $5m in escrow until they get the ok from IRS that there is no tax (i.e. i have a similar thought as you, there hopefully is no tax due to all the losses but then again its US tax laws which I am not familiar with). So the hopefully they will later distribute the escrowed $5m to holders after this is confirmed.

For the remaining value of the shell, i think they havent disclosed specifically the working capital + interest repayments so there could be another 2-$4m but i think they wont provide clarity until the transaction is voted in. But i am of the similar opinion that this could be worth 10 cents+.

The top 20 is pretty stacked so i am pretty sure it will go through.