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 to the Partners in the same manner as each correlative item of income, gain, loss or deduction, 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 Adjusted Property are required to be allocated to the Partners in the same manner as under section 704(c) of the Code (as specified in sections 1.704-1(b)(2)(iv)(f), 1.704-1(b)(2)(iv)(g) and 1.704-3 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 Adjusted Property. Thus, notwithstanding anything in Sections 3.1 or 3.2(a) hereof to the contrary, the Partners' distributive shares of Tax Items in respect of each Adjusted Property shall be separately determined and allocated to the Partners following any permissible method under 1.704-3 of the Regulations reasonably selected by the General Partner, and the Capital Account balances of the Partners shall be adjusted solely for allocations of book items in respect of such assets and shall not be adjusted for their distributive shares of any corresponding Tax Items.

Allocation of Tax Items. (a) Except as otherwise provided in the succeeding provisions of this Section 3.2, each Tax Item shall be allocated to among the Partners in the same manner as each correlative item of income, gain, loss profit or deductionloss, 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 Adjusted any Book/Tax Disparity Property owned by the Partnership are required to be allocated to 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)(f), 1(b)(2)(iv) and 1.704-1(b)(2)(iv)(g) and 1.704-3 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 Adjusted Book/Tax Disparity Property. Thus, notwithstanding anything in Sections Section 3.1 or 3.2(a) hereof to the contrary, the Partners' ’ distributive shares of Tax Items in respect of each Adjusted Book/Tax Disparity Property shall be separately determined and allocated to among the Partners following any permissible method under 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 1.704-3 of 1(b)(2)(iv) if a Revaluation Event occurs) the Regulations reasonably selected General Partner shall determine the method or methods to be used by the General Partner, and the Capital Account balances of the Partners shall be adjusted solely for allocations of book items in respect of such assets and shall not be adjusted for their distributive shares of any corresponding Tax ItemsPartnership.

Allocation of Tax Items. (a) Except as otherwise provided in the succeeding provisions of this Section SECTION 3.2, each Tax Item shall be allocated to the Partners in the same manner as each correlative item of income, gain, loss or deduction, as calculated for book purposes, is allocated pursuant to the provisions of Section SECTION 3.1 hereof. (b) The Partners hereby acknowledge that all Tax Items in respect of Adjusted Property are required to be allocated to the Partners in the same manner as under section 704(c) of the Code (as specified in sections 1.704-1(b)(2)(iv)(f), 1.704-1(b)(2)(iv)(g) and 1.704-3 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 Adjusted Property. Thus, notwithstanding anything in Sections SECTIONS 3.1 or 3.2(a) hereof to the contrary, the Partners' distributive shares of Tax Items in respect of each Adjusted Property shall be separately determined and allocated to the Partners following any permissible method under 1.704-3 of the Regulations reasonably selected by the General Partner, and the Capital Account balances of the Partners shall be adjusted solely for allocations of book items in respect of such assets and shall not be adjusted for their distributive shares of any corresponding Tax Items.

Allocation of Tax Items. (a) Except as otherwise provided in the succeeding provisions of this Section 3.2, each Tax Item shall be allocated to among the Partners in the same manner as each correlative item of income, gain, loss profit or deductionloss, as calculated for book purposes, is allocated pursuant to the provisions of Section 3.1 hereof. . 9 <PAGE> (b) The Partners hereby acknowledge that all Tax Items in respect of Adjusted any Book/Tax Disparity Property owned by the Partnership are required to be allocated to 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)(f), 1(b)(2)(iv) and 1.704-1(b)(2)(iv)(g) and 1.704-3 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 Adjusted Book/Tax Disparity Property. Thus, notwithstanding anything in Sections Section 3.1 or 3.2(a) hereof to the contrary, the Partners' distributive shares of Tax Items in respect of each Adjusted Book/Tax Disparity Property shall be separately determined and allocated to among the Partners following any permissible method under 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 1.704-3 of 1(b)(2)(iv) if a Revaluation Event occurs), the Regulations reasonably selected General Partner in its sole discretion shall determine the method or methods to be used by the General Partner, and the Capital Account balances of the Partners shall be adjusted solely for allocations of book items in respect of such assets and shall not be adjusted for their distributive shares of any corresponding Tax ItemsPartnership.