Allocation of Book Items. Before the allocations of Profits or Losses (or items thereof) pursuant to Section 2.1(h), the following special allocations shall be made in the following order:
(a) Pursuant to section 1.704-2(f) of the Regulations (relating to minimum gain chargebacks), if there is a net decrease in Nonrecourse Minimum Gain of the Partnership for the Allocation Year (or if there was a net decrease in Nonrecourse Minimum Gain for a prior Allocation Year and the Partnership did not have sufficient amounts of income or gain during the Allocation Year to allocate to the Partners under this Section 2.1(a)), then items of Partnership income or gain shall be allocated, before any other allocation is made pursuant to the succeeding provisions of this Section 2.1 for such year, to each Partner in proportion to, and to the extent of, the total net decrease in such Partner’s share of the Nonrecourse Minimum Gain (determined and adjusted in accordance with the provisions of section 1.704-2(g) of the Regulations). As provided in section 1.704-2(j) of the Regulations, income of the Partnership allocated for any Allocation Year under this Section 2.1(a) shall consist first of a pro rata portion of gain recognized from the disposition of Partnership property subject to a Nonrecourse Liability and discharge of indebtedness income relating to the Nonrecourse Liability to which the Property is subject, with any remaining allocated income deemed to be made up of a pro rata portion of the Partnership’s other items of income and items of gain for such year (provided that gain from the disposition of property which is subject to Partner Nonrecourse Debt and discharge of indebtedness income relating to the Partner Nonrecourse Debt to which the Property is subject shall be allocated under this Section 2.1(a) only to the extent not allocated under Section 2.1(b) hereof).
(b) Pursuant to section 1.704-2(i)(4) of the Regulations (relating to partner nonrecourse minimum gain chargebacks), if there is a net decrease in Partner Nonrecourse Minimum Gain of the Partnership for such taxable year or other period (or if there was a net decrease in Partner Nonrecourse Minimum Gain for a prior taxable year or other period and the Partnership did not have sufficient amounts of income during prior taxable year or other period to allocate to the Partners under this Section 2.1(b)), then items of Partnership income and gain shall be allocated, before any other allocation is made pursuant to the succeeding provi...
Allocation of Book Items. In cases where Partnership Property is, under Treas. Reg. (Section) 1.704-1(b)(2)(iv), properly reflected in the capital accounts of the Partners and Unitholders at a fair market value that differs from the adjusted basis of such property (such difference is hereinafter referred to as the "Book Disparity"), then depreciation, amortization and gain or loss as computed for book purposes with respect to such property ("Book Depreciation," "Book Amortization," "Book Gain," and "Book Loss," respectively) will be greater or less than the depreciation, amortization or gain or loss as computed for tax purposes. The General Partners shall adopt, pursuant to Treas. Reg. (Section) 1.704-1(b)(2)(iv)(g), a reasonable method of computing Book Depreciation and Book Amortization. Such Book Amortization and Book Depreciation shall be allocated among the Partners and Unitholders and reflected in Partners' and Unitholders' capital accounts under Paragraph 11.11(c) hereof, in a manner so as to eliminate to the extent possible, the Book Disparity.
Allocation of Book Items. In cases where Partnership Property is, under Treas. Reg. Section 1.704- 1(b)(2)(iv), properly reflected in the capital accounts of the Partners at a fair market value that differs from the adjusted basis of such property (such difference is hereinafter referred to as the "Book Disparity"), then depreciation, amortization and gain or loss as computed for book purposes with respect to such property ("Book Depreciation," "Book Amortization," "Book Gain" and "Book Loss," respectively) will be greater or less than the depreciation, amortization or gain or loss as computed for tax purposes. The Managing General Partner shall adopt, pursuant to Treas. Reg. Section 1.704-1(b)(2)(iv)(g), a reasonable method of computing Book Depreciation and Book Amortization. Such Book Depreciation and Book Amortization shall be allocated among the Partners and reflected in Partners' capital accounts under Paragraph 11.3(c) hereof, in a manner so as to eliminate, to the extent possible, the Book Disparity.
Allocation of Book Items. In cases where property of the Trust is, under Treas. Reg. Section 1.704-1(b)(2)(iv)(g), properly reflected in the Capital Accounts of the Shareholders at a fair market value that differs from the adjusted tax basis of such property (such difference is hereinafter referred to as the "Book Disparity"), then depreciation, amortization and gain or loss as computed for book purposes with respect to such property ("Book Depreciation," "Book Amortization," and "Book Gain," and "Book Loss," respectively) will be greater or less than the depreciation, amortization or gain or loss as computed for tax purposes. The Manager shall adopt, pursuant to Treas.
Allocation of Book Items. In cases where Partnership Property is under Treas. Reg. Sections 1.704-1(b)(2)(iv),properly reflected in the capital accounts of the Partners at a fair market value that differs from the adjusted basis of such property (such difference is hereinafter referred to as the "Book Disparity"), then depreciation, amortization and gain or loss as computed for book purposes with respect to such property ("Book Depreciation," "Book Amortization," "Book Gain," and "Book Loss," respectively) will be greater or less than the depreciation, amortization or gain or loss as computed for tax purposes. Book Depreciation and Book Amortization for any year with respect to a Partnership Property is the amount that bears the same relationship to the value for book purposes of such Property as the depreciation or amortization computed for tax purposes bears to the adjusted tax basis of such Property. If such Property has a zero tax basis, Book Depreciation and Book Amortization may be calculated under any reasonable method selected by the Managing General Partner.
Allocation of Book Items. The adjusted tax basis of Trust Assets may be adjusted in the reasonable discretion of the Tax Matters Partner to equal their respective gross fair market values, as reasonably determined by the Tax Matters Partner, at the times specified in Treas. Reg. §1.704-1(b)(2)(iv)(f). In cases where property of the Trust is, under Treas. Reg. §1.704-1(b)(2)(iv)(g), properly reflected in the Capital Account of a Holder at a fair market value that differs from the adjusted tax basis of such property (such difference is hereinafter referred to as the “Book Disparity”), then depreciation, amortization and gain or loss as computed for book purposes with respect to such property (“Book Depreciation,” “Book Amortization,” “Book Gain,” and “Book Loss,” respectively) will be greater or less than the depreciation, amortization or gain or loss as computed for tax purposes. The Tax Matters Partner shall adopt, pursuant to Treas. Reg. §1.704-l(b)(2)(iv)(g), a reasonable method of computing Book Depreciation and Book Amortization. Such Book Depreciation and Book Amortization shall be allocated among the Holders and reflected in the Holders’ Capital Account under Section 10.03, in a manner so as to eliminate, to the extent possible, the Book Disparity.
