Allocation for Federal Income Tax Purposes. For U.S. federal income tax purposes, the Concession Payment is allocated between the right to toll the Toll Lanes and rent under the lease for Project Right of Way based on the relative fair market values of such rights as of the Effective Date, which are 80% and 20%, respectively.
Allocation for Federal Income Tax Purposes. Income or loss of the Partnership for federal income tax purposes only shall be allocated in each fiscal year in the following manner:
Allocation for Federal Income Tax Purposes. For U.S. federal income tax purposes, the Refinancing Gain payment to TxDOT is allocated between the right to toll the Toll Lanes and rent for Project Right of Way based on the relative fair market values of such rights as of the Effective Date, which are 80% and 20%, respectively.
Allocation for Federal Income Tax Purposes. The Members acknowledge and agree that for federal and state income tax purposes each Member will be treated as owning an undivided interest in each asset or liability of the Company in accordance with the Sharing Ratio. The basis of each Member in such assets will reflect the federal income tax basis of the property contributed to the Company and the amount of any increase or decrease in the basis of each Member’s investment in the Company as determined for federal income tax purposes.
Allocation for Federal Income Tax Purposes. (A) For federal income tax purposes, except as otherwise provided in Section 10.04, all items of Company income, gain, loss, and deduction with respect to a taxable year of the Company shall be allocated to the Members as follows:
