Common use of Allocation of Certain Tax Items Clause in Contracts

Allocation of Certain Tax Items. As stated in Treasury Regulations Section 1.704-1(b)(4)(i), when any property of the Partnership is reflected in the Capital Accounts of the Partners and on the books of the Partnership at a book value that differs from the adjusted tax basis of such property, then certain book items with respect to such property will differ from certain tax items with respect to that property. Since the Capital Accounts of the Partners are required to be adjusted solely for allocation of the book items, the Partners’ shares of the corresponding tax items are not independently reflected by adjustments to the Capital Accounts. These tax items must be shared among the Partners in a manner that takes account of the variation between the adjusted tax basis of the applicable property and its book value in the same manner as variations between the adjusted tax basis and fair market value of property contributed to the Partnership are taken into account in determining the Partners’ share of tax items under Code Section 704(c). In making allocations of tax items of the Partnership, the Partnership shall comply with the foregoing principles.

Allocation of Certain Tax Items. As stated set forth in Treasury Regulations Section 1.704-1(b)(4)(il(b)(4)(i), when any property of the Partnership Company is reflected in the Capital Accounts of the Partners Members and on the books of the Partnership Company at a book value that differs from the adjusted tax basis of such property, then certain book items with respect to such property will differ from certain tax items with respect to that property. Since the Capital Accounts of the Partners Members are required to be adjusted solely for allocation of the book items, the PartnersMembers’ shares of the corresponding tax items are not independently reflected by adjustments to the Capital Accounts. These tax items must be shared among the Partners Members in a manner that takes account of the variation between the adjusted tax basis of the applicable property and its book value in the same manner as variations between the adjusted tax basis and fair market value of property contributed to the Partnership Company are taken into account in determining the PartnersMembers’ share of tax items under Code Section 704(c). In making allocations of tax items of the PartnershipCompany, the Partnership Company shall comply with the foregoing principles.

Allocation of Certain Tax Items. As stated set forth in Treasury Regulations Section 1.704-1(b)(4)(i), when any property of the Partnership Company is reflected in the Capital Accounts of the Partners Members and on the books of the Partnership Company at a book value that differs from the adjusted tax basis of such property, then certain book items with respect to such property will differ from certain tax items with respect to that property. Since the Capital Accounts of the Partners Members are required to be adjusted solely for allocation of the book items, the PartnersMembers’ shares of the corresponding tax items are not independently reflected by adjustments to the Capital Accounts. These tax items must be shared among the Partners Members in a manner that takes account of the variation between the adjusted tax basis of the applicable property and its book value in the same manner as variations between the adjusted tax basis and fair market value of property contributed to the Partnership Company are taken into account in determining the PartnersMembers’ share of tax items under Code Section 704(c). In making allocations of tax items of the PartnershipCompany, the Partnership Company shall comply with the foregoing principles.