Common use of Allocation for Tax Purposes Clause in Contracts

Allocation for Tax Purposes. For each fiscal year, items of income, deduction, gain, loss or credit shall be allocated for income tax purposes among the Partners in such manner as to reflect equitably amounts credited or debited to each Partner's Capital Account for the current and prior fiscal years (or relevant portions thereof). Allocations under this Sec. 3.09 shall be made pursuant to the principles of Section 704(c) of the Internal Revenue Code of 1986, as amended (the "Code"), and in conformity with Regulations Sections 1.704-1(b)(2)(iv)(f) and 1.704-1(b)(4)(i) promulgated thereunder, or the successor provisions to such Section and Regulations. Notwithstanding anything to the contrary in this Agreement, there shall be allocated to the Partners such gains or income as shall be necessary to satisfy the "qualified income offset" requirement of Regulations Section 1.704-1(b)(2)(ii)(d).

Allocation for Tax Purposes. For each fiscal year, year ----------------------------------------- items of income, deduction, gain, loss or credit shall be allocated allo- cated for income tax purposes among the Partners in such manner as to reflect equitably amounts credited or debited to each Partner's Capital Account for the current and prior fiscal years Fiscal Years (or relevant portions thereof). Allocations under this Sec. 3.09 Section 3.06 shall be made pursuant to the principles of Section 704(b) and 704(c) of the Internal Revenue Code of 1986, as amended (the "Code"), and in conformity with Regulations Sections 1.704-1(b)(2)(iv)(f1.704- (b)(2)(iv)(f) and 1.704-1(b)(4)(i) and 1.704-3(e) promulgated thereunder, as applicable, or the successor provisions to such Section and Regulations. Notwithstanding anything to the contrary in this Agreement, there shall be allocated to the Partners such gains or income as shall be necessary to satisfy the "qualified income offset" requirement of Regulations Section 1.704-1(b)(2)(ii)(d).

Allocation for Tax Purposes. For each fiscal year, year ----------------------------------------- items of income, deduction, gain, loss or credit shall be allocated allo- cated for income tax purposes among the Partners in such manner as to reflect equitably amounts credited or debited to each PartnerPart- ner's Capital Account for the current and prior fiscal years Fiscal Years (or relevant portions thereof). Allocations under this Sec. 3.09 Section 3.06 shall be made pursuant to the principles of Section 704(b) and 704(c) of the Internal Revenue Code of 1986, as amended (the "Code"), and in conformity with Regulations Sections 1.704-1.704- 1(b)(2)(iv)(f) and 1.704-1(b)(4)(i) and 1.704-3(e) promulgated thereunder, as applicable, or the successor provisions to such Section and Regulations. Notwithstanding anything to the contrary con- trary in this Agreement, there shall be allocated to the Partners such gains or income as shall be necessary to satisfy the "qualified quali- fied income offset" requirement of Regulations Section 1.704-1(b)(2)(ii)(d).

Allocation for Tax Purposes. (a) For each fiscal tax year, items of income (including items of gross income), deduction, gain, loss or credit shall be allocated for income tax purposes among the Partners in such manner as to reflect equitably amounts credited to or debited to from each Partner's Capital Account Account(s) for the current and prior fiscal years (or relevant portions thereof). Allocations under this Sec. Section 3.09 shall be made pursuant to the principles of Section 704(b) and 704(c) of the Internal Revenue Code of 1986, as amended (the "Code"), and in conformity with Treasury Regulations Sections 1.704-1(b)(2)(iv)(f) and (g), 1.704-1(b)(4)(i) and 1.704-3(e) promulgated thereunder, as applicable, or the successor provisions to such Section and Treasury Regulations. Notwithstanding anything to the contrary in this Agreement, there shall be allocated to the Partners such gains or income as shall be necessary to satisfy the "qualified income offset" requirement requirements of Treasury Regulations Section 1.704-1(b)(2)(ii)(d).

Allocation for Tax Purposes. For each fiscal year, year ----------------------------------------- items of income, deduction, gain, loss or credit shall be allocated allo- cated for income tax purposes among the Partners in such manner as to reflect equitably amounts credited or debited to each Partner's Capital Account for the current and prior fiscal years Fiscal Years (or relevant portions thereof). Allocations under this Sec. 3.09 Section 3.06 shall be made pursuant to the principles of Section 704(b) and 704(c) of the Internal Revenue Code of 1986, as amended (the "Code"), and in conformity with Regulations Sections 1.704-1.704- 1(b)(2)(iv)(f) and 1.704-1(b)(4)(i) and 1.704-3(e) promulgated thereunder, as applicable, or the successor provisions to such Section and Regulations. Notwithstanding anything to the contrary con- trary in this Agreement, there shall be allocated to the Partners such gains or income as shall be necessary to satisfy the "qualified quali- fied income offset" requirement of Regulations Section 1.704-1(b)(2)(ii)(d).