If there is a merger (which was referenced in PIP filing): http://files.shareholder.com/downloads/ABEA-3QV6OO/0x0x833738/21644E81-1542-47D9-A623-B57ABF754A74/SC1-_3872138-v7-Tax_Consequences_to_Kraft_Shareholders_2_.pdf
If it is just an extraordinary dividend: http://www.investmentnews.com/article/20120923/REG/309239966/the-tax-implications-of-special-dividends
1. SIGA, with an asset at one time valued in the billions, raises $300M in funding and makes a buyout offer to PIP at more than 100% premium to its current market value. Entities merge, NOLs preserved, SIGA's thorn in its side is taken out once and for all and it picks up PIP pipeline. (This appears far better than just raising funds to payoff the judgment in my opinion).
2. PIP makes a buyout offer to SIGA for $100M at more than 100% premium to its current market value. Deal is financed with SIGA cash on hand/receivables and due to PIP per the DSC judgment. Entities merge, NOLs preserved, PIP's thorn in its side is taken out once and for all, and it has operation control over an asset at one time valued in the billions. Even if it is rejected, the SP of SIGA jumps significantly and makes it easier for them to raise funds with less dilution (i.e. PIP helps PIP get PAID).
Either way, a combined market value for these entities at less than $200M seems laughable, assuming ST-246 still has potential in the U.S. and abroad.