Common use of and Revaluation Allocations Clause in Contracts

and Revaluation Allocations. In accordance with Code Section 704(c) and the Treasury Regulations thereunder, income, gain, loss and deduction 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 its fair market value at the time of contribution. In the event of a revaluation, subsequent allocations of income, gain, loss and deduction with respect to such property shall take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its fair market value immediately after the adjustment in the same manner as under Code Section 704(c) and the Treasury Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Board of Directors in a manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 5.3 are solely for income tax purposes and shall not affect, or in any way be taken into account in computing, for book purposes, any Member's Capital Account or share of Profit or Loss, pursuant to any provision of this Operating Agreement. The Tax Matters Member shall have no authority to make any allocation without prior approval of the Board of Directors.

and Revaluation Allocations. In accordance with Code Section § 704(c) and the Treasury Regulations thereunder, income, gain, loss and deduction with respect to any property contributed to the capital of the Company shallwill, 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 its fair market value Fair Value at the time of contribution. In the event of a revaluationRevaluation, subsequent allocations of income, gain, loss and deduction with respect to such property shall will take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its fair market value Fair Value immediately after the adjustment in the same manner as under Code Section § 704(c) and the Treasury Regulations thereunder. Any elections or other decisions relating to such allocations shall will be made by the Board of Directors Representative in a manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 5.3 4.5(a) are solely for income tax purposes and shall will not affect, or in any way be taken into account in computing, for book purposes, any Member's ’s Capital Account or share of Profit Income or Loss, pursuant to any provision of this Operating Agreement. The Tax Matters Member shall have no authority to make any allocation without prior approval of the Board of Directors.

and Revaluation Allocations. In accordance with Code Section IRC §704(c) and the Treasury Regulations thereunder, income, gain, loss and deduction with respect to any property Property contributed to the capital of the Company DFS 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 Property to the Company DFS for federal income tax purposes and its fair market value Fair Value at the time of contribution. In the event of a revaluationRevaluation, subsequent allocations of income, gain, loss and deduction with respect to such property any Property shall take account of any variation between the adjusted basis of such property to the Company DFS for federal income tax purposes and its fair market value Fair Value immediately after the adjustment in the same manner as under Code Section IRC §704(c) and the Treasury Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Board of Directors Members in a manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 5.3 4.1(c) are solely for income tax purposes and shall not affect, or in any way be taken into account in computing, for book purposes, any Member's ’s Capital Account or share of Profit Income or Loss, pursuant to any provision of this Operating Agreement. The Tax Matters Member shall have no authority to make any allocation without prior approval of the Board of Directors.

and Revaluation Allocations. In accordance with Code Section § 704(c) and the Treasury Regulations thereunder, income, gain, loss and deduction 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 its fair market value at the time of contribution. In the event of a revaluationRevaluation, subsequent allocations of income, gain, loss and deduction with respect to such property shall take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its fair market value immediately after the adjustment in the same manner as under Code Section § 704(c) and the Treasury Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Board of Directors Managers in a manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 5.3 4.6(a) are solely for income tax purposes and shall not affect, or in any way be taken into account in computing, for book purposes, any Member's ’s Capital Account or share of Profit Income or Loss, pursuant to any provision of this Operating Agreement. The Tax Matters Member shall have no authority to make any allocation without prior approval of the Board of Directors.

and Revaluation Allocations. In accordance with Code Section 704(c) and the Treasury Regulations thereunder, income, gain, loss and deduction 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 its fair market value Fair Value at the time of contribution. In the event of a revaluationRevaluation, subsequent allocations of income, gain, loss and deduction with respect to such property shall take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its fair market value Fair Value immediately after the adjustment in the same manner as under Code Section 704(c) and the Treasury Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Board of Directors Management Committee in a manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 5.3 4.5(a) are solely for income tax purposes and shall not affect, or in any way be taken into account in computing, for book purposes, any Member's Capital Account or share of Profit Income or Loss, pursuant to any provision of this Operating Agreement. The Tax Matters Member shall have no authority to make any allocation without prior approval of the Board of Directors.

and Revaluation Allocations. In accordance with Code Section § 704(c) and the Treasury Regulations thereunder, income, gain, loss and deduction with respect to any property contributed to the capital of the Company shallwill, 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 its fair market value Fair Value at the time of contribution. In the event of a revaluationRevaluation, subsequent allocations of income, gain, loss and deduction with respect to such property shall will take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its fair market value Fair Value immediately after the adjustment in the same manner as under Code Section § 704(c) and the Treasury Regulations thereunder. Any elections or other decisions relating to such allocations shall must be made by the Board of Directors Management Committee in a manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 5.3 4.5(a) are solely for income tax purposes and shall will not affect, or in any way be taken into account in computing, for book purposes, any Member's ’s Capital Account or share of Profit Income or Loss, pursuant to any provision of this Operating Agreement. The Tax Matters Member shall have no authority to make any allocation without prior approval of the Board of Directors.

and Revaluation Allocations. In accordance with Code Section 704(c) and the Treasury Regulations thereunder, income, gain, loss and deduction 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 its fair market value at the time of contribution. In the event of a revaluationRevaluation, subsequent allocations of income, gain, loss and deduction with respect to such property shall take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its fair market value immediately after the adjustment in the same manner as under Code Section § 704(c) and the Treasury Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Board of Directors Manager in a manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 5.3 3(A) are solely for income tax purposes and shall not affect, or in any way be taken into account in computing, for book purposes, any Member's ’s Capital Account or share of Profit Income or Loss, Loss pursuant to any provision of this Operating Agreement. The Tax Matters Member shall have no authority to make any allocation without prior approval of the Board of Directors.