Allocation of Recapture Items. In making any allocation among the Members of income or gain from the sale or other disposition of a Company asset, the ordinary income portion, if any, of such income and gain resulting from the recapture of cost recovery or other deductions shall be allocated among those Members in a manner consistent with Treasury Regulations Section 1.1245 -1(e).
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Samples: Limited Liability Company Agreement (Trilogy International Partners Inc.), Limited Liability Company Agreement (Trilogy International Partners Inc.), Limited Liability Company Agreement (SG Enterprises, II LLC)
Allocation of Recapture Items. In making any allocation among the Members Unitholders of income or gain from the sale or other disposition of a Company asset, the ordinary income portion, if any, of such income and gain resulting from the recapture of cost recovery or other deductions shall will be allocated among those Members Unitholders who were previously allocated (or whose predecessors-in-interest were previously allocated) the cost recovery deductions or other deductions resulting in a manner consistent the recapture items, in accordance with Treasury Regulations Section 1.1245 -1(e)1.1245-1.
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Samples: Limited Liability Company Agreement (Zabala Farms Group, LLC)
Allocation of Recapture Items. In making any allocation among the Members of income or gain from the sale or other disposition of a Company asset, the ordinary income portion, if any, of such income and gain resulting from the recapture of cost recovery or other deductions shall be allocated among those Members parties who were previously allocated (or whose predecessors-in-interest were previously allocated) the cost recovery deductions or other deductions resulting in a manner consistent the recapture items, in accordance with Treasury Regulations Regulation Section 1.1245 -1(e)1.1245-1.
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Allocation of Recapture Items. In making any allocation among the Members of income or gain from the sale or other disposition of a Company asset, the ordinary income portion, if any, of such income and gain resulting from the recapture of cost recovery or other deductions shall be allocated among those Members in a manner consistent with Treasury Regulations Section 1.1245 -1(e1.1245-1(e).
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Samples: Limited Liability Company Agreement (Horwitz Bradley J)