ALLOCATIONS RESPECTING. Section 704(c) and Revaluations. Notwithstanding Section 4.4(b), Tax Items with respect to Partnership property that are subject to Code Section 704(c) and/or Regulation Section 1.704-3 (collectively “Section 704(c) Tax Items”) shall, to the extent so required, be allocated in accordance with said Code section and/or Regulation Section 1.704-3, as the case may be. The Partners are authorized to specially allocate Tax Items consistent with the principles of Regulation Section 1.704-3.
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Samples: Partnership Agreement (General Trust Co), Partnership Agreement (General Trust Co)
ALLOCATIONS RESPECTING. Section 704(c) and Revaluations. Notwithstanding Section 4.4(b)paragraph (a) hereof, Tax Items with respect items that relate to Partnership property that are is subject to Code Section section 704(c) (contributed property having a fair market value different from its tax basis) and/or revalued pursuant to Regulation Section 1.704-3 1 (b)(2)(iv)(f) (collectively “"Section 704(c) Tax Items”") shall, to the extent so required, shall be allocated in accordance with said Code section and/or 704(c) and Regulation Section 1.704-3, as the case may be. The Partners are General Partner is authorized to specially allocate Tax Items consistent with select the principles of method under Regulation Section 1.704-33 for the allocation of Section 704(c) Tax items.
Appears in 1 contract
Samples: Limited Partnership Agreement (Strategic Timber Trust Inc)
ALLOCATIONS RESPECTING. Section 704(c) and Revaluations. Notwithstanding Section 4.4(b)paragraph (a) hereof, Tax Items with respect items that relate to Partnership property that are is subject to Code Section section 704(c) (contributed property having a fair market value different from its tax basis) and/or revalued pursuant to Regulation Section 1.704-3 1(b)(2)(iv)(f) (collectively “"Section 704(c) Tax Items”") shall, to the extent so required, shall be allocated in accordance with said Code section and/or 704(c) and Regulation Section 1.704-3, as the case may be. The Partners are General Partner is authorized to specially allocate Tax Items consistent with select the principles of method under Regulation Section 1.704-33 for the allocation of Section 704(c) Tax items.
Appears in 1 contract
Samples: Limited Partnership Agreement (Strategic Timber Trust Inc)