Common use of Minimum Gain Clause in Contracts

Minimum Gain. The term "Minimum Gain" shall mean the amount determined by (i) computing for each Nonrecourse Liability of the Partnership any gain the Partnership would realize if it disposed of the property subject to that liability for no consideration other than full satisfaction of the liability and (ii) aggregating the separately computed gains, as described in Regulations sections 1.704-1(b)(2)(iv) and 1.704-2(d), Partnership property is properly reflected on the books of the Partnership at a value different from the adjusted tax basis of such property, the calculation of Minimum Gain pursuant to the preceding sentence shall be made by reference to such book value.

Appears in 2 contracts

Samples: Limited Partnership Agreement (Gaylord Entertainment Co /De), Gaylord Entertainment Co /De

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Minimum Gain. The term "Minimum Gain" shall mean the amount determined by (i) computing for each Nonrecourse Liability of the Partnership any gain the Partnership would realize if it disposed of the property subject to that liability for no consideration other than full satisfaction of the liability and (ii) aggregating the separately computed gains, as described in Regulations sections 1.704I.704-1(b)(2)(ivl(b)(2)(iv) and 1.704I.704-2(d), Partnership property is properly reflected on the books of the Partnership at a value different from the adjusted tax basis of such property, the calculation of Minimum Gain pursuant to the preceding sentence shall be made by reference to such book value.

Appears in 1 contract

Samples: Limited Partnership Agreement (RHP Partner, LLC)

Minimum Gain. The term "Minimum Gain" shall mean the amount determined by (i) computing for each Nonrecourse Liability of the Partnership any gain the Partnership would realize if it disposed of the property subject to that liability for no consideration other than full satisfaction of the liability and (ii) aggregating the separately computed gains. If, as described in pursuant to Regulations sections section 1.704-1(b)(2)(iv1(b)(2)(iv)(d) and or 1.704-2(d1(b)(2)(iv)(f), Partnership property is properly reflected on the books of the Partnership at a value different from the adjusted tax basis of such property, the calculation of Minimum Gain pursuant to the preceding sentence shall be made by reference to such book value.

Appears in 1 contract

Samples: Partnership Agreement (Gaylord Entertainment Co /De)

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Minimum Gain. The term "Minimum Gain" shall mean the amount determined by (i) computing for each Nonrecourse Liability of the Partnership any gain the Partnership would realize if it disposed of the property subject to that liability for no consideration other than full satisfaction of the liability and (ii) aggregating the separately computed gains, as described in Regulations sections 1.704-1(b)(2)(ivl(b)(2)(iv) and 1.704-2(d), Partnership property is properly reflected on the books of the Partnership at a value different from the adjusted tax basis of such property, the calculation of Minimum Gain pursuant to the preceding sentence shall be made by reference to such book value.

Appears in 1 contract

Samples: Limited Partnership Agreement (RHP Partner, LLC)

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