Allocations With Respect to Contributed Property. Notwithstanding any other provision of this Agreement to the contrary, items of income, gain, loss, and deduction with respect to property contributed to the Partnership by any Partner shall be allocated among the Partners so as to take into account the variation between the basis of the property to the Partnership and its fair market value at the time of contribution in accordance with the requirements of Section 704(c) of the Code and applicable Regulations thereunder.
Allocations With Respect to Contributed Property. Allocation of ------------------------------------------------ book and tax items with respect to property contributed by any Member shall be made solely for Federal income tax purposes as required by section 704(c) of the Code using the traditional method. Following any revaluation of the Company's assets and the adjustment of any Member's Capital Account pursuant to Regulations section 1.704-1(b)(2)(iv)(f) to reflect such revaluation, the Members' Capital Accounts shall be adjusted for various items as computed for book purposes with respect to such revalued assets as required by Regulations section 1.704-1(b) and the Members' shares of such items as computed for tax purposes with respect to such items shall be determined as required by Regulations section 1.704-1(b). Income or Losses upon the disposition of any property contributed to the Company shall be determined with respect to the book basis of such property instead of its income tax basis.
Allocations With Respect to Contributed Property. Asset Value ------------------------------------------------------------- Adjustments. -----------
Allocations With Respect to Contributed Property. Notwithstanding any other provision of this Agreement to the contrary (and consistent with Section 4.05), items of income, gain, loss, and deduction with respect to property contributed to the Company by any Member shall be allocated among the Members so as to take into account the variation between the basis of the property to the Company and its fair market value at the time of contribution in accordance with the requirements of Section 704(c) of the Code and applicable Regulations thereunder.
Allocations With Respect to Contributed Property. Solely for federal and applicable state income tax purposes, income, gain, loss and deduction with respect to property shall be allocated so as to take into account the difference, if any, between the Book Value of the property and its Adjusted Basis. The preceding sentence shall be administered in accordance with the traditional method under Section 1.704-3(b) of the Treasury Regulations.
Allocations With Respect to Contributed Property. The Tax Items with respect to any property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and the agreed fair market value of such property, in accordance with Code Section 704(c) and the Regulations thereunder. All allocations required or permitted by Code Section 704(c) will be made using any method that is permissible under the applicable Regulations as determined by the Board, including without limitation the “remedial method” in accordance with Regulations § 1.704-3(d).
