Allocation of Profits and Losses Tax and Accounting Matters. Section 7.1 Allocations. Each Member’s distributive share of income, gain, loss, deduction or credit (or items thereof) of the Company as shown on the annual federal income tax return prepared by the Company’s accountants or as finally determined by the United States Internal Revenue Service or the courts, and as modified by the capital accounting rules of Section 704(b) of the Code and the Income Tax Regulations thereunder, as applicable, shall be determined as follows:
Allocation of Profits and Losses Tax and Accounting Matters. (a) General Allocations. Each Partner's distributive share of the Joint Venture's income, gain, loss, deduction or credit (or items thereof) as shown on the annual federal income tax return prepared in accordance with Section 6.4(b) of this Agreement or as finally determined by the United States Internal Revenue Service or the courts, and as modified by the capital accounting rules of section 704(b) of the Code and the Income Tax Regulations thereunder, shall be determined as follows:
Allocation of Profits and Losses Tax and Accounting Matters
