Zeta Corporation is interested in acquiring Tau Corporation through a "Type A" reorganization on January 2 of the current year. Zeta is valued at $50 million and generates taxable income of $5 million per year, whereas Tau is valued at $7 million and holds a $1.47 million NOL with none years remaining in its carryover period. If Zeta earns a 7% after-tax rate of return and the Federal long-term tax-exempt rate is 3%, what value should Zeta place on Tau's NOL?