APPLICATION FOR WAIVER. In the event that the Company determines that the application of the provision of Section 3.04(a) or Section 3.04(b) would cause a distortion in the economic arrangement among the Members, the Managing Member may, on behalf of the Company, request a waiver of the application of either or both of such provisions pursuant to Treas. Reg. Section 1.704-2(f) (4) or Treas. Reg. Section 1.704-2(i) (4).
Appears in 3 contracts
Samples: Limited Liability Company Agreement (Rouse Properties, Inc.), Limited Liability Company Agreement (Rouse Properties, Inc.), Limited Liability Company Agreement (Rouse Properties, Inc.)
APPLICATION FOR WAIVER. In the event that the Company Managing Member determines that the application of the provision provisions of Section 3.04(a) or Section 3.04(b) of this Appendix would cause a distortion in the economic arrangement among the Members, the Managing Member may, on behalf of the Company, request a waiver of the application of either or both of such provisions pursuant to Treas. Reg. Section §1.704-2(f) (42(f)(4) or Treas. Reg. Section §1.704-2(i) (42(i)(4).
Appears in 3 contracts
Samples: Operating Agreement, Operating Agreement, Operating Agreement
APPLICATION FOR WAIVER. In the event that the Company determines Manager ---------------------- determines, in its reasonable discretion, that the application of the provision provisions of Section 3.04(a) or Section 3.04(b) would cause a distortion in the economic arrangement among the Members, the Managing Member Manager may, on behalf of the Company, request a waiver of the application of either or both of such provisions pursuant to Treas. Reg. Section (S) 1.704-2(f) (4) or Treas. Reg. Section 1.704-2(i) (42(f)(4).
Appears in 2 contracts
Samples: Members Agreement (Ebs Litigation LLC), Members Agreement (Ebs Pension LLC)
APPLICATION FOR WAIVER. In the event that the Company determines Manager determines, in its reasonable discretion, that the application of the provision provisions of Section 3.04(a) or Section 3.04(b) would cause a distortion in the economic arrangement among the Members, the Managing Member Manager may, on behalf of the Company, request a waiver of the application of either or both of such provisions pursuant to Treas. Reg. Section 1.704-2(f) (42(f)(4) or Treas. Reg.
Section 1. Section 1.704704-2(i) (42(i)(4).
Appears in 2 contracts
Samples: Members Agreement (Ebs Building LLC), Members' Agreement (Stratosphere Corp)
APPLICATION FOR WAIVER. In the event that the Company Board of Managers determines that the application of the provision provisions of Section 3.04(a) or Section 3.04(b) of this Appendix A would cause a distortion in the economic arrangement among the Members, the Managing Member any Officer may, on behalf of the Company, request a waiver of the application of either or both of such provisions pursuant to Treas. Reg. Section § 1.704-2(f) (42(f)(4) or Treas. Reg. Section § 1.704-2(i) (42(i)(4).
Appears in 1 contract
APPLICATION FOR WAIVER. In the event that the Company Manager determines that the application of the provision provisions of Section 3.04(a) or Section 3.04(b) of this Appendix B would cause a distortion in the economic arrangement among the Members, the Managing Member any Officer may, on behalf of the Company, request a waiver of the application of either or both of such provisions pursuant to Treas. Reg. Section 1.704-2(f) (42(f)(4) or Treas. Reg. Section 1.704-2(i) (42(i)(4).
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Allegheny Energy Inc)