Common use of Allocation of Tax Items Clause in Contracts

Allocation of Tax Items. (a) Except as otherwise provided in the succeeding provisions of this Section 3.2, each Tax Item shall be allocated among the Partners in the same manner as each correlative item of profit or loss, as calculated for book purposes, is allocated pursuant to the provisions of Section 3.1 hereof. (b) The Partners hereby acknowledge that all Tax Items in respect of any Book/Tax Disparity Property owned by the Partnership are required to be allocated among the Partners in the same manner as under section 704(c) of the Code (as specified in sections 1.704-1(b)(2)(iv) and 1.704-1(b)(2)(iv)(g) of the Regulations) and that the principles of section 704(c) of the Code require that such Tax Items must be shared among the Partners so as to take account of the variation between the adjusted tax basis and Book Basis of each such Book/Tax Disparity Property. Thus, notwithstanding anything in Section 3.1 or 3.2(a) hereof to the contrary, the Partners' distributive shares of Tax Items in respect of each Book/Tax Disparity Property shall be separately determined and allocated among the Partners in accordance with the principles of section 704(c) of the Code. For purposes of making tax allocations pursuant to section 704(c) of the Code (including allocations pursuant to Section 1.704-1(b)(2)(iv) if a Revaluation Event occurs), the General Partner in its sole discretion shall determine the method or methods to be used by the Partnership.

Allocation of Tax Items. (a) Except as otherwise provided in the succeeding provisions of this Section 3.2, each Tax Item shall be allocated among the Partners in the same manner as each correlative item of profit or loss, as calculated for book purposes, is allocated pursuant to the provisions of Section 3.1 hereof. (b) The Partners hereby acknowledge that all Tax Items in respect of any Book/Tax Disparity Property owned by the Partnership are required to be allocated among the Partners in the same manner as under section 704(c) of the Code (as specified in sections 1.704-1(b)(2)(iv) and 1.704-1(b)(2)(iv)(g) of the Regulations) and that the principles of section 704(c) of the Code require that such Tax Items must be shared among the Partners so as to take account of the variation between the adjusted tax basis and Book Basis of each such Book/Tax Disparity Property. Thus, notwithstanding anything in Section 3.1 or 3.2(a) hereof to the contrary, the Partners' ’ distributive shares of Tax Items in respect of each Book/Tax Disparity Property shall be separately determined and allocated among the Partners in accordance with the principles of section 704(c) of the Code. For purposes of making tax allocations pursuant to section 704(c) of the Code (including allocations pursuant pursuant, to Section 1.704-1(b)(2)(iv) if a Revaluation Event occurs), the General Partner in its sole discretion shall determine the method or methods to be used by the Partnership.

Allocation of Tax Items. (a) Except as otherwise provided in the succeeding provisions of this Section 3.2, each Tax Item shall be allocated among the Partners Members in the same manner as each correlative item of profit or loss, as calculated for book purposes, is allocated pursuant to the provisions of Section 3.1 and Section 3.4 hereof. (b) The Partners Members hereby acknowledge that all Tax Items in respect of any Book/Tax Disparity Property owned by the Partnership Company are required to be allocated among the Partners Members in the same manner as under section Section 704(c) of the Code (as specified in sections Sections 1.704-1(b)(2)(iv1(b)(2)(iv)(f) and 1.704-1(b)(2)(iv)(g) of the Regulations) and that the principles of section Section 704(c) of the Code require that such Tax Items must be shared among the Partners Members so as to take account of the variation between the adjusted tax basis and Book Basis of each such Book/Tax Disparity Property. Thus, notwithstanding anything in Section Sections 3.1 or 3.2(a3.2 (a) hereof to the contrary, the Partners' Members’ distributive shares of Tax Items in respect of each Book/Tax Disparity Property shall be separately determined and allocated among the Partners Members in accordance with the principles of section Section 704(c) of the Code. For purposes of making tax allocations pursuant to section Section 704(c) of the Code (including allocations pursuant to Section 1.704-1(b)(2)(iv1(b)(2)(iv)(f) if a Revaluation Event occurs), ) the General Partner in its sole discretion Manager shall determine the method or methods to be used by the PartnershipCompany.

Allocation of Tax Items. (a) Except as otherwise provided in the succeeding provisions of this Section 3.2, each Tax Item shall be allocated among the Partners in the same manner as each correlative item of profit or loss, as calculated for book purposes, is allocated pursuant to the provisions of Section 3.1 hereof. (b) The Partners hereby acknowledge that all Tax Items in respect of any Book/Tax Disparity Property owned by the Partnership are required to be allocated among the Partners in the same manner as under section 704(c) of the Code (as specified in sections 1.704-1(b)(2)(iv) and 1.704-1(b)(2)(iv)(g) of the Regulations) and that the principles of section 704(c) of the Code require that such Tax Items must be shared among the Partners so as to take account of the variation between the adjusted tax basis and Book Basis of each such Book/Tax Disparity Property. Thus, notwithstanding anything in Section 3.1 or 3.2(a) hereof to the contrary, the Partners' ’ distributive shares of Tax Items in respect of each Book/Tax Disparity Property shall be separately determined and allocated among the Partners in accordance with the principles of section 704(c) of the Code. For purposes of making tax allocations pursuant to section 704(c) of the Code (including allocations pursuant pursuant, to Section 1.704-1(b)(2)(iv1.704.1(b)(2)(iv) if a Revaluation Event occurs), the General Partner in its sole discretion shall determine the method or methods to be used by the Partnership.

Allocation of Tax Items. (a) Except as otherwise provided in the succeeding provisions of this Section 3.2, each Tax Item shall be allocated among the Partners in the same manner as each correlative item of profit or loss, as calculated for book purposes, is allocated pursuant to the provisions of Section 3.1 hereof. (b) The Partners hereby acknowledge that all Tax Items in respect of any Book/Tax Disparity Property owned by the Partnership are required to be allocated among the Partners in the same manner as under section 704(c) of the Code (as specified in sections 1.704-1(b)(2)(ivl(b)(2)(iv)(f) and 1.704-1(b)(2)(iv)(g1 (b)(2)(iv)(g) of the Regulations) and that the principles of section 704(c) of the Code require that such Tax Items must be shared among the Partners so as to take account of the variation between the adjusted tax basis and Book Basis of each such Book/Tax Disparity Property. Thus, notwithstanding anything in Section 3.1 or 3.2(a) hereof to the contrary, the Partners' distributive shares of Tax Items in respect of each Book/Tax Disparity Property shall be separately determined and allocated among the Partners in accordance with the principles of section 704(c) of the Code. For purposes of making tax allocations pursuant to section 704(c) of the Code (including allocations pursuant to Section 1.704-1(b)(2)(iv1(b)(2)(iv)(f) if a Revaluation Event occurs), ) the General Partner in its sole discretion shall determine the method or methods to be used by the Partnership.

Allocation of Tax Items. (a) Except as otherwise provided in the succeeding provisions of this Section 3.2, each Tax Item shall be allocated among the Partners in the same manner as each correlative item of profit or loss, as calculated for book purposes, is allocated pursuant to the provisions of Section 3.1 hereof. (b) The Partners hereby acknowledge that all Tax Items in respect of any Book/Tax Disparity Property owned by the Partnership are required to be allocated among the Partners in the same manner as under section Section 704(c) of the Code (as specified in sections Sections 1.704-1(b)(2)(iv) and 1.704-1(b)(2)(iv)(g) of the Regulations) and that the principles of section Section 704(c) of the Code require that such Tax Items must be shared among the Partners so as to take account of the variation between the adjusted tax basis and Book Basis of each such Book/Tax Disparity Property. Thus, notwithstanding anything in Section 3.1 or 3.2(a) hereof to the contrary, the Partners' distributive shares of Tax Items in respect of each Book/Tax Disparity Property shall be separately determined and allocated among the Partners in accordance with the principles of section Section 704(c) of the Code. For purposes of making tax allocations pursuant to section 704(c) of the Code (including allocations pursuant to Section 1.704-1(b)(2)(iv) if a Revaluation Event occurs), the General Partner in its sole discretion shall determine the method or methods to be used by the Partnership.of