Allocation of Partner Nonrecourse Deductions. Notwithstanding any other provisions of the Agreement, any item of Partner Nonrecourse Deduction with respect to a Partner Nonrecourse Debt will be allocated to the Partner or Partners who bear the economic risk loss for such Partner Nonrecourse Debt in accordance with Treasury Regulations § 1.704-2(i).
Appears in 5 contracts
Samples: Partnership Agreement (Special Value Continuation Partners, LP), Partnership Agreement (Special Value Continuation Partners, LP), Partnership Agreement (Special Value Continuation Fund, LLC)
Allocation of Partner Nonrecourse Deductions. Notwithstanding any other provisions of the Agreement, any item of Partner Nonrecourse Deduction with respect to a Partner Nonrecourse Debt will Deductions shall be specially allocated to the Partner or Partners who bear bears the economic risk of loss for with respect to the Partner Nonrecourse Debt to which such Partner Nonrecourse Debt Deductions are attributable in accordance with Treasury Regulations § Section 1.704-2(i2(i)(1).
Appears in 3 contracts
Samples: Letter Agreement, Letter Agreement, Letter Agreement
Allocation of Partner Nonrecourse Deductions. Notwithstanding any other provisions of the Agreement, any item of Partner Nonrecourse Deduction with respect to a Partner Nonrecourse Debt will be allocated to the Partner or Partners who bear the economic risk loss for such Partner Nonrecourse Debt in accordance with Treasury Regulations § ss. 1.704-2(i).
Appears in 2 contracts
Samples: Partnership Agreement (Special Value Continuation Partners, LP), Partnership Agreement (Tennenbaum Opportunities Partners V, LP)
Allocation of Partner Nonrecourse Deductions. Notwithstanding any other provisions of the Agreement, any item of Partner Nonrecourse Deduction with respect to a Partner Nonrecourse Debt will shall be allocated to the Partner or Partners who bear the economic risk loss for such Partner Nonrecourse Debt in accordance with Treasury Regulations § Treas. Reg. Section 1.704-2(i).
Appears in 1 contract
Samples: Agreement (WTNH Broadcasting Inc)