Allocation of Book Items. Subject to the provisions of Sections 3.2 and 3.3, all items of profit and loss realized by the Partnership during each fiscal year shall be allocated among the Partners (after giving effect to all adjustments attributable to all contributions and distributions of money and property effected during such year) in the manner prescribed in this Section 3.1.
Allocation of Book Items. In cases where property of the Trust is, under Treas. Reg. ss. 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. Reg. ss. 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 Shareholders and reflected in the Shareholders' capital accounts under Section 9.4 hereof, in a manner so as to eliminate to the extent possible, the Book Disparity.
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:
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. Subject to the provisions of Section 4.2, all items of profit and loss realized by Palace during each Fiscal Year shall be allocated among the Members (after giving effect to all adjustments attributable to all contributions and distributions of money and property effected during such Fiscal Year) in the manner prescribed in SECTION 4.1.
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. Subject to the provisions of Sections 3.2 and 3.3, all items of profit and loss realized by the Partnership during each fiscal year shall be allocated among the Partners (after giving effect to all adjustments attributable to all contributions and distributions of money and property effected during such year) in the manner prescribed in this Section 3.1. (a) Pursuant to section 1.704-2(f) of the Regulations (relating to minimum gain chargebacks), if there is a net decrease in Partnership Minimum Gain for such year (or if there was a net decrease in Partnership Minimum Gain for a prior fiscal year and the Partnership did not have sufficient amounts of Gross Income and Book Gain during prior years to allocate among the Partners under this Section 3.1), then items of Gross Income and Book Gain shall be allocated, before any other allocation is made pursuant to the succeeding provisions of this Section 3.1 for such year, to each Partner in an amount equal to such Partner's share of the net decrease in such Partnership Minimum Gain (as determined under sections 1.704-2(g)(2) of the Regulations). This Section 3.1(a) is intended to comply with the minimum gain chargeback requirement in Section 1.704-2(f) of the Regulations, and shall be interpreted consistently therewith. (b) Pursuant to section 1.704-2(i)(4) of the Regulations (relating to minimum gain chargebacks), if there is a net decrease in Partner Nonrecourse Debt Minimum Gain with respect to a Partner Nonrecourse Debt for such year (or if there was a net decrease in such Partner Nonrecourse Debt Minimum Gain for a prior fiscal year and the Partnership did not have sufficient amounts of Gross Income and Book Gain during prior years to allocate among the Partners under this Section 3.1(b)), then items of Gross Income and Book Gain shall be allocated, before any other allocation is made pursuant to the succeeding provisions of this Section 3.1 for such year, to each Partner with a share of such Partner Nonrecourse Debt Minimum Gain as of the first day of such year in an amount equal to such Partner's share of the net decrease in such Partner Nonrecourse Debt Minimum Gain (as required by sections 1.704-2(i)(4) of the Regulations). (c) Pursuant to section 1.704-1(b)(2)(ii)(d) of the Regulations (relating to "qualified income offsets"), Partnership profit shall be allocated, before any other allocation is made pursuant to the succeeding provisions of this Section 3.1 for such year, among the Partners with defic...
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.
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.
