1. Investor Relations
Bank of America Corporate Center
101 N. Tryon St
Charlotte, NC 28255
Federal Income Tax Consequences of the Exchange of MBNA Common Stock (KRB) to
Bank of America (BAC) Common Stock and Cash
Please refer to pages 49 - 51 of the Form S-4 Registration/Proxy Statement dated August
2, 2005 for a complete description of the material federal income tax consequences of the
merger of MBNA with Bank of America. The Proxy Statement was mailed to all
MBNA shareholders on or about August 3, 2005. Our discussion assumes that your investment in
MBNA stock was held as a capital asset. Also note that there are specific circumstances in which
this general description of the federal income tax consequences may not apply. Please see the
above mentioned Proxy Statement for additional details. This document also does not address
any state tax consequences to you from the merger. Per the merger agreement, each
outstanding share of MBNA common stock was converted into 1) $4.125 in cash and 2) .5009
shares of Bank of America common stock. Fractional shares were paid in cash.
When you received the combination of Bank of America common stock and cash for your
MBNA shares, only the cash portion of your merger consideration was subject to tax if
the value of the Bank of America common stock and cash received exceeded the tax
basis of your MBNA stock. Other than with respect to the cash received, the exchange of
MBNA stock for Bank of America common stock was not currently taxable.
To calculate your potential taxable gain, you first need to determine the “amount realized”
on the exchange, which is the sum of the fair market value of the stock and cash received.
Then, you compare the tax basis in your MBNA shares with this amount realized. The
amount by which the amount realized exceeds your tax basis equals the “gain realized”.
You will recognize income on your 2006 tax return equal to the lesser of: (1) the amount of
cash received, or (2) the gain realized. If the amount realized is less than your tax basis in
the MBNA shares, you will have a loss which cannot be recognized until you sell your
Bank of America stock.
The tax basis in your MBNA shares carries over to the Bank of America shares you
received in the merger. In addition, you should add to your new Bank of America stock
basis the amount of gain recognized for tax purposes, subtract the cash received in the
exchange (do not include the cash received for a fractional share), and subtract the portion
of basis allocated to the fractional share deemed exchanged for cash.
The holding period of the Bank of America shares you received includes the period during
which you held your MBNA stock.
The cash received in exchange for a fractional share results in a tax gain or loss recognized
based on the difference between the amount of cash received in lieu of the fractional share
and the portion of your tax basis which is allocable to the fractional share. Cash received
for a fractional share is either taxable as a long-term or short-term capital gain depending
on how long you held your MBNA shares. If you held the MBNA shares for more than
one year, your gain is long-term capital gain. If you held the MBNA shares for less than
one year, your gain is short-term capital gain.
PLEASE NOTE THAT BANK OF AMERICA CANNOT AND DOES NOT GIVE TAX

2. ADVICE. BANK OF AMERICA TAKES NO RESPONSIBILITY FOR THE INFORMATION
CONTAINED HEREIN. WE HIGHLY RECOMMEND THAT YOU SEEK PROFESSIONAL TAX
ADVICE TO CALCULATE THE TAX CONSEQUENCES OF YOUR EXCHANGE OF MBNA
COMMON STOCK FOR BANK OF AMERICA COMMON STOCK AND CASH.
THE ABOVE INFORMATION IS NOT INTENDED OR WRITTEN TO BE USED, AND
CANNOT BE USED BY ANY SHAREHOLDER, FOR THE PURPOSE OF AVOIDING TAX-
RELATED PENALTIES UNDER FEDERAL, STATE OR LOCAL TAX LAW. EACH
SHAREHOLDER SHOULD SEEK ADVICE BASED ON ITS PARTICULAR
CIRCUMSTANCES FROM AN INDEPENDENT TAX ADVISOR.

3. Three Examples Based on Long- term Ownership of 100 shares of MBNA (KRB) Stock
Example 1 Tax basis of 100 shares of MBNA @ $ 20.00 per share $ 2,000.00
Example 2 Tax basis of 100 shares of MBNA @ $ 25.00 per share $ 2,500.00
Example 3 Tax basis of 100 shares of MBNA @ $ 30.00 per share $ 3,000.00
Merger Consideration:
MBNA shareholders, for each share of MBNA they owned, received:
1) 0.5009 shares of Bank of America (BAC) common stock
2) fractional shares in cash
3) $ 4.125 Cash
Bank of America stock price (closing price on 12/30/05) $ 46.15
Calculation of taxable gain on exchange of MBNA shares:
Tax Basis of MBNA stock
$ 20.00 $ 25.00 $ 30.00
Merger consideration:
Stock (.5009 x 100 shares of MBNA stock = 50.09 BAC shares) 50.09 $ 2,311.65 $ 2,311.65 $ 2,311.65
Cash ($4.125 X 100 shares) 412.50 412.50 412.50
Amount Realized $ 2,724.15 $ 2,724.15 $ 2,724.15
Tax basis in MBNA shares $ 2,000.00 $ 2,500.00 $ 3,000.00
Gain (Loss) realized $ 724.15 $ 224.15 $ (275.85)
Taxable Gain (equal to lessor of 1) cash received or 2) gain realized 412.50 $ 224.15 $ -
(1) (2) (3)
Note 1 Cash is less than gain recognized
Note 2 Realized gain is less than the cash received
Note 3 No loss should be recognized on date of exchange
Tax basis of Bank of America stock received (50.09)
Tax Basis of MBNA stock
$ 20.00 $ 25.00 $ 30.00
Tax basis in MBNA shares $ 2,000.00 $ 2,500.00 $ 3,000.00
Add gain recognized 412.50 $ 224.15 $ -
Less cash received (412.50) (412.50) (412.50)
Tax basis in Bank of America shares received (50.09) $ 2,000.00 $ 2,311.65 $ 2,587.50
Less basis allocated to fractional share of BAC stock for cash 3.59 4.15 4.65
Net basis in Bank of America shares retained (50 shares) $ 1,996.41 $ 2,307.50 $ 2,582.85
Basis Per Bank of America share $ 39.93 $ 46.15 $ 51.66
Calculation of gain (loss) on fractional share
(A)
Fractional share proceeds (.09 x $46.42 ) $ 4.18 $ 4.18 $ 4.18
(B)
Basis $ 3.59 $ 4.15 $ 4.65
Gain (Loss) $ 0.58 $ 0.02 $ (0.47)
(A)
Average of the closing price of BAC stock for the five trading days immediately preceding the closing date
(B)
A portion of the Bac stock basis is allocable to the fractional shares (.09/50.09 x new BAC basis = fractional shares)
The above information is not intended or written to be used, and cannot be used by any shareholder, for the purpose
of avoiding tax-related penalties under federal, state, or local tax law. Each shareholder should seek advice based on
its particular circumstances from an independent tax advisor.