Allocations of Tax Items. (a) Items of income, deduction, gain and loss that are recognized by the Company for federal income tax purposes shall be allocated among the Members consistent with the allocations of such items under Sections 6.1 and 6.2. To the extent appreciation or depreciation in asset values is reflected in Capital Accounts prior to recognition for tax purposes, allocations shall be made in accordance with the principles and provisions of Section 704(c) of the Code.
Appears in 3 contracts
Samples: Limited Liability Company Agreement, Limited Liability Company Agreement (Imperial Capital Group, Inc.), Limited Liability Company Agreement (Imperial Capital Group, Inc.)
Allocations of Tax Items. (a) Items of income, deduction, gain and loss that are recognized by the Company Partnership for federal income tax purposes shall be allocated among the Members Partners consistent with the allocations of such items under Sections 6.1 4.1 and 6.24.2. To the extent appreciation or depreciation in asset values is reflected in Capital Accounts prior to recognition for tax purposes, allocations shall be made in accordance with the principles and provisions of Code Section 704(c) of the Code).
Appears in 2 contracts
Samples: Limited Partnership Agreement (Imperial Capital Group, Inc.), Limited Partnership Agreement (Imperial Capital Group, Inc.)
