Allocations for Income Tax Purposes. The income, gains, losses, deductions and credits of the Partnership for Federal, state and local income tax purposes shall be allocated in the same manner as the corresponding items entering into the computation of Net Income and Net Losses were allocated pursuant to Section 4.1 and 4.2, provided that solely for Federal, state and local income and franchise tax purposes and not for book or Capital Account purposes, income, gain, loss and deduction with respect to property properly carried on the Partnership’s books at a value other than its tax basis shall be allocated in accordance with the requirements of Code Section 704(c) and Treasury Regulations § 1.704-3.
Appears in 6 contracts
Samples: Limited Partnership Agreement (America First Tax Exempt Investors Lp), Limited Partnership Agreement (America First Tax Exempt Investors Lp), Limited Partnership Agreement (America First Tax Exempt Investors Lp)
Allocations for Income Tax Purposes. The income, gains, losses, deductions and credits of the Partnership for Federal, state and local income tax purposes shall be allocated in the same manner as the corresponding items entering into the computation of Net Income and Net Losses were allocated pursuant to Section Sections 4.1 and 4.2, provided that solely for Federal, state and local income and franchise tax purposes and not for book or Capital Account purposes, income, gain, loss and deduction with respect to property properly carried on the Partnership’s books at a value other than its tax basis shall be allocated in accordance with the requirements of Code Section 704(c704 (c) and Treasury Regulations § 1.704-3, using any method permitted by the Treasury Regulations that the General Partner deems to be appropriate.
Appears in 2 contracts
Samples: Agreement of Limited Partnership, Agreement of Limited Partnership (Vistancia Marketing, LLC)
Allocations for Income Tax Purposes. The income, gains, losses, deductions and credits of the Partnership for Federal, state and local income tax purposes shall be allocated in the same manner as the corresponding items entering into the computation of Net Income and Net Losses were allocated pursuant to Section Sections 4.1 and 4.2, provided that solely for Federal, state and local income and franchise tax purposes and not for book or Capital Account purposes, income, gain, loss and deduction with respect to property properly carried on the Partnership’s books at a value other than its tax basis shall be allocated in accordance with the requirements of Code Section 704(c) and Treasury Regulations § §1.704-3.
Appears in 2 contracts
Samples: Limited Partnership Agreement, Limited Partnership Agreement
Allocations for Income Tax Purposes. The income, gains, losses, deductions and credits of the Partnership Company for Federal, state and local income tax purposes shall be allocated in the same manner as the corresponding items entering into the computation of Net Income and Net Losses were allocated pursuant to Section Sections 4.1 and 4.2, provided that solely for Federal, state and local income and franchise tax purposes and not for book or Capital Account purposes, income, gain, loss and deduction with respect to property properly carried on the PartnershipCompany’s books at a value other than its tax basis shall be allocated in accordance with the requirements of Code Section 704(c) and Treasury Regulations § §1.704-3.
Appears in 1 contract
Samples: Operating Agreement
Allocations for Income Tax Purposes. The income, gains, losses, deductions and credits of the Partnership for Federal, state and local income tax purposes shall be allocated in the same manner as the corresponding items entering into the computation of Net Income and Net Losses were allocated pursuant to Section Sections 4.1 and 4.2, provided that solely for Federal, state and local income and franchise tax purposes and not for book or Capital Account purposes, income, gain, loss and deduction with respect to property properly carried on the Partnership’s books at a value other than its tax basis shall be allocated in accordance with the requirements of Code Section section 704(c) and Treasury Regulations § 1.704-3.
Appears in 1 contract
Samples: Limited Liability Limited Partnership Agreement (Cintas Corp)
Allocations for Income Tax Purposes. The income, gains, losses, deductions and credits of the Partnership for Federal, state and local income tax purposes shall be allocated in the same manner as the corresponding items entering into the computation of Net Income and Net Losses were allocated pursuant to Section Sections 4.1 and 4.2, provided that solely for Federal, state and local income and franchise tax purposes and not for book or Capital Account purposes, income, gain, loss and deduction with respect to property properly carried on the Partnership’s books at a value other than its tax basis shall be allocated in accordance with the requirements of Code Section 704(c) and Treasury Regulations § Section 1.704-3, using any method permitted by the Treasury Regulations that the General Partner deems to be appropriate.
Appears in 1 contract
Samples: Agreement of Limited Partnership (Shea Homes Limited Partnership)
Allocations for Income Tax Purposes. (a) The income, gains, losses, deductions and credits of the Partnership for Federalfederal, state and local income tax purposes shall be allocated in the same manner as the corresponding items entering into the computation of Net Income and Net Losses were allocated pursuant to Section 4.1 Sections 3.03 and 4.2, 3.04; provided that solely for Federalfederal, state and local income and franchise tax purposes and not for book or Capital Account purposes, income, gain, loss and deduction with respect to property properly carried on the Partnership’s 's books at a value other than its tax basis shall be allocated in accordance with the requirements of Code Section section 704(c) and Treasury Regulations § section 1.704-33 of the Regulations thereunder.
Appears in 1 contract
Samples: Limited Partnership Agreement (Dapham Partnership Lp)