Adjustment of Tax Basis. Upon the transfer of an interest in the Company, the Company may, at the sole discretion of the Managers, elect pursuant to Section 754 of the Internal Revenue Code of 1986, as amended, to adjust the basis of the Company property as allowed by Sections 734(b) and 743(b) thereof.
Adjustment of Tax Basis. Upon the transfer of an interest in the Partnership, the Partnership may, at the sole discretion of the General Partners, elect pursuant to Section 754 of the Internal Revenue Code of 1986, as amended, to adjust the basis of the Partnership property as allowed by Sections 734(b) and 743(b) thereof.
Adjustment of Tax Basis. Upon the transfer of an interest in the Partnership, the Partnership may, at the sole discretion of the General Partners, elect, pursuant to Section 754 of the Internal Revenue Code of 1954, as amended, to adjust the basis of the Partnership property as allowed by Section 734(b) and 743(b) thereof. The election, if made, will be filed with the Partnership information income tax return for the first taxable year to which the election applies.
Adjustment of Tax Basis. In the event of a transfer of an Interest in accordance with the terms of this Agreement, upon the request of any Partner, the General Partner may, in its sole discretion, cause the Partnership to elect, pursuant to Section 754 of the Code (“Section 754 Election”), to adjust the basis of the Partnership property if (a) the effect of such adjustment is to increase the adjusted basis of Partnership property and (b) such requesting Partner agrees to bear any additional expense attributable to accounting and recordkeeping required as a result of the Partnership’s Section 754 Election.
Adjustment of Tax Basis. In the event of a Transfer or in the event of a distribution of assets of the Partnership to any Partner, the Partnership, in the absolute discretion of the General Partner, may, but is not required to, file an election under Section 754 of the Code and in accordance with the applicable Regulations, to cause the basis of the Partnership’s assets to be adjusted for federal income tax purposes as provided by Sections 734 or 743 of the Code.
Adjustment of Tax Basis. 14 4.07 INSURANCE.......................................................................................... 15 4.08 APPRAISALS......................................................................................... 15 4.08
Adjustment of Tax Basis. Profits and Losses described in Section 6.3(e) shall be allocated in a manner consistent with the manner that the adjustments to the Capital Accounts are required to be made pursuant to Treasury Regulation section 1.704-1(b)(2)(iv)(j), (k) and (m).
Adjustment of Tax Basis. The Company shall in all appropriate cases, as determined by the Manager and subject to the prior written approval and consent of All Members, elect pursuant to Section 754 of the Code to adjust the basis of the Company property as allowed by Code Section 734(b) and 743(b). These elections will be filed as and when required by the Code.
Adjustment of Tax Basis. 18 4.07 Insurance........................................................................................................ 19 4.08 Appraisals....................................................................................................... 19
Adjustment of Tax Basis. 18 10.6 CONTROVERSIES WITH INTERNAL REVENUE SERVICE............................18 ARTICLE XI..................................................................18 CAPITAL ACCOUNTS; ALLOCATIONS; TAX DISTRIBUTIONS............................18
