Allocations With Respect to Property. Solely for tax purposes, in determining each Member’s allocable share of the taxable income or loss of the Company, depreciation, depletion, amortization and gain or loss with respect to any contributed property, or with respect to revalued property where the Company’s property is revalued pursuant to paragraph (b)(2)(iv)(f) of Section 1.704-1 of the Income Tax Regulations, shall be allocated to the Members in the manner (as to revaluations, in the same manner as) provided in Section 704(c) of the Code. The allocation shall take into account, to the full extent required or permitted by the Code, the difference between the adjusted basis of the property to the Member contributing it (or, with respect to property which has been revalued, the adjusted basis of the property to the Company) and the fair market value of the property determined by the Members at the time of its contribution or revaluation, as the case may be.
Allocations With Respect to Property. Solely for tax purposes, in determining each Partner's allocable share of the taxable income or loss of the Partnership, depreciation, depletion, amortization and gain or loss with respect to any contributed property, or with respect to revalued property where the Partnership's property is revalued pursuant to paragraph (b)(2)(iv)(f) of section 1.704-1 of the Regulations, shall be allocated to the Partners under the remedial method as provided under Section 1.704-3(d) of the Regulations.
Allocations With Respect to Property. In accordance with section 704(c) of the Code and sections 1.704-1(b)(2)(iv)(g) and 1.704-3(b) of the Income Tax Regulations, items of income, gain, loss, and deduction with respect to any property contributed to the capital of the Joint Venture shall, solely for tax purposes, be allocated among the Partners in a manner consistent with section 1.704-3(b) of the Income Tax Regulations so as to take into account to the full extent required or permitted by the Code, the difference between the adjusted basis of the property to the Partner contributing it and the fair market value of the property determined by the Partners at the time of its contribution or revaluation, as the case may be.
