Allocation in Event of Transfer. If an interest in the Partnership is transferred in accordance with Article 7 of this Agreement, the Net Profit and Net Loss of the Partnership and each item thereof, and all other items attributable to the transferred interest for such Fiscal Year, shall be divided and allocated between the transferor and the transferee pursuant to the interim closing of the Partnership books method set forth in Treasury Regulation Section 1.706-1(c)(2)(ii) unless the parties otherwise mutually agree. This Section shall apply for purposes of computing a Partner's Capital Account and for federal income tax purposes.
Appears in 2 contracts
Samples: Contribution and Formation Agreement (Insight Capital Inc), Insight Communications Co Inc
Allocation in Event of Transfer. If an interest in the Partnership is transferred in accordance with Article 7 8 or 9 of this Agreement, the Net Profit and Net Loss of the Partnership and each item thereof, and all other items attributable to the transferred interest for such Fiscal Year, shall be divided and allocated between the transferor and the transferee pursuant to the interim closing of the Partnership books method set forth in Treasury Regulation Section 1.706-1(c)(2)(ii) unless the parties otherwise mutually agree. This Section shall apply for purposes of computing a Partner's Capital Account and for federal income tax purposes.
Appears in 2 contracts
Allocation in Event of Transfer. If an interest in the Partnership is transferred in accordance with Article 7 12 of this Agreement, the Net Profit Income and Net Loss of the Partnership and each item thereof, and all other items attributable to the transferred interest for such Fiscal Year, shall be divided and allocated between the transferor and the transferee pursuant to the interim closing of the Partnership books method set forth in Treasury Regulation Section 1.706-1(c)(2)(ii) unless the parties otherwise mutually agree. This Section shall apply for purposes of computing a Partner's Capital Account and for federal income tax purposes.
Appears in 1 contract
Samples: Adelphia Communications Corp