Allocations Under Regulations. (a) Company Nonrecourse Deductions. Loss attributable (under Treasury Regulation Section 1.704-2(c)) to "partnership nonrecourse liabilities" (within the meaning of Treasury Regulation Section 1.704-2(b)(1)) shall be allocated among the Members in the same proportion as their respective Membership Interests.
Appears in 2 contracts
Sources: Operating Agreement (Cotelligent Inc), Operating Agreement (Cotelligent Inc)
Allocations Under Regulations. (a) Company Nonrecourse Deductions. Loss attributable (under Treasury Regulation Section 1.704-2(c)) to "partnership nonrecourse liabilities" (within the meaning of Treasury Regulation Section 1.704-2(b)(1)) shall be allocated among the Members in the same proportion as their respective Membership Percentage Interests.
Appears in 1 contract
Sources: Operating Agreement (Crown Castle International Corp)
Allocations Under Regulations. (a) Company Nonrecourse Deductions. Loss attributable (under Treasury Regulation Regulations Section 1.704-2(c)) to "partnership nonrecourse liabilities" (within the meaning of Treasury Regulation Regulations Section 1.704-2(b)(1)) shall be allocated among the Members in the same proportion as their respective Membership Interests.
Appears in 1 contract