Allocations to Capital Accounts. (a) Except as provided in Section 7.2(b) or elsewhere in this Agreement, Tax Items for any fiscal year shall be allocated among the Members in a manner such that the Capital Account of each Member, immediately after giving effect to such allocation, is, as nearly as possible, equal (proportionately) to the amount equal to the distributions that would be made to such Member during such fiscal year pursuant to Section 6.1. The Managing Member may, in its discretion, make such assumptions as it deems necessary or appropriate in order to effectuate the intended economic arrangement of the Members.
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Samples: Limited Liability Company Operating Agreement (Secured Real Estate Income Strategies, LLC), Limited Liability Company Operating Agreement (Secured Real Estate Income Fund II, LLC), Limited Liability Company Operating Agreement (Secured Real Estate Income Fund II, LLC)