Common use of As provided in Treas Clause in Contracts

As provided in Treas. Reg. §1.704-1(b)(2)(iv)(e), upon distribution of Partnership property (other than cash) to a Party the capital accounts will be adjusted to reflect the manner in which the unrealized income, gain, loss and deduction inherent in distributed property (not previously reflected in the capital accounts) would be allocated among the Parties if there were a disposition of such property at its FMV as of the time of distribution. Furthermore, if so agreed to in Section 9.2, under the rules of Treas. Reg. § 1.704-1(b)(2)(iv)(f), the FMV capital accounts shall be revalued at certain times to reflect value changes of the Partnership property, and allocations for tax purposes under Section 6.2.1 shall thereafter be made as necessary in accordance with the second sentence thereof and the principles of Code §704(c).

As provided in Treas. Reg. §1.704ss.1.704-1(b)(2)(iv)(e), upon distribution of Partnership property (other than cash) to a Party the capital accounts will be adjusted to reflect the manner in which the unrealized income, gain, loss and deduction inherent in distributed property (not previously reflected in the capital accounts) would be allocated among the Parties if there were a disposition of such property at its FMV as of the time of distribution. Furthermore, if so agreed to in Section Sec. 9.2, under the rules of Treas. Reg. § 1.704-1(b)(2)(iv)(fss. 1.7041 (b)(2)(iv)(f), the FMV capital accounts shall be revalued at certain times to reflect value changes of the Partnership property, and allocations for tax purposes under Section 6.2.1 shall thereafter be made as necessary in accordance with the second sentence thereof and the principles of Code §704(c).. JOA - Exhibit "F"

As provided in Treas. Reg. §§ 1.704-1(b)(2)(iv)(e), upon distribution of Tax Partnership property (other than cash) to a Party the capital accounts will be adjusted to reflect the manner in which the unrealized income, gain, loss and deduction inherent in distributed property (not previously reflected in the capital accounts) would be allocated among the Parties if there were a taxable disposition of such property at its FMV as of the time of distribution. Furthermore, if so agreed to in Section 9.2, under the rules of Treas. Reg. § 1.704-1(b)(2)(iv)(f), the FMV capital accounts shall be revalued at certain times to reflect value changes of the Tax Partnership property, and allocations for tax purposes under Section 6.2.1 shall thereafter be made as necessary in accordance with the second sentence thereof and the principles of Code §704(c).

As provided in Treas. Reg. §1.704ss.1.704-1(b)(2)(iv)(e), upon distribution of Partnership property (other than cash) to a Party the capital accounts will be adjusted to reflect the manner in which the unrealized income, gain, loss and deduction inherent in distributed property (not previously reflected in the capital accounts) would be allocated among the Parties if there were a disposition of such property at its FMV as of the time of distribution. Furthermore, if so agreed to in Section Sec. 9.2, under the rules of Treas. Reg. § 1.704-1(b)(2)(iv)(fss. 1.704 1 (b)(2)(iv)(f), the FMV capital accounts shall be revalued at certain times to reflect value changes of the Partnership property, and allocations for tax purposes under Section 6.2.1 shall thereafter be made as necessary in accordance with the second sentence thereof and the principles of Code §704(c).