Basis Adjustments. To the extent an adjustment to the ----------------- adjusted tax basis of any Partnership asset pursuant to Code Section 734 (b) or Code Section 743 (b) is required under Regulation Section 1. 704 -1(b) (2)(iv)(m) to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment. increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Regulations; provided, however, in the event that an adjustment to the Book Value of Partnership property is made as a result of an adjustment pursuant to Section 734 (b) of the Code, items of income, gain, loss or deduction, as computed for book and tax purposes, shall be specially allocated among the Partners so that the effect of any such adjustment shall benefit (or be borne by) the Partner(s) receiving the distribution which caused such adjustment.
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Samples: Petro Stopping Centers L P
Basis Adjustments. To the extent an adjustment to the ----------------- adjusted tax basis of any Partnership asset pursuant to Code Section 734 (b) or Code Section 743 (b) is required under Regulation Section 1. 704 -1(b) (2)(iv)(m) to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment. increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Regulations; provided, however, in the event that an adjustment to the Book Value of Partnership property is made as a result of an adjustment pursuant to Section 734 (b) of the Code, items of income, gain, loss or deduction, as computed for book and tax purposes, shall be specially allocated among the Partners so that the effect of any such adjustment shall benefit (or be borne by) the Partner(s) receiving the distribution which caused such adjustment.
Appears in 1 contract
Basis Adjustments. To the extent an adjustment to the adjusted ----------------- adjusted tax basis of any Partnership asset pursuant to Code Section 734 (b734(b) or Code Section 743 (b743(b) is required under Regulation Section 1. 704 -1(b) (2)(iv)(m1.704-1(b)(2)(iv)(m) to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment. increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Regulations; provided, however, in the event that an adjustment to the Book Value of Partnership property is made as a result of an adjustment pursuant to Section 734 (b) of the Code, items of income, gain, loss or deduction, as computed for book and tax purposes, shall be specially allocated among the Partners so that the effect of any such adjustment shall benefit (or be borne by) the Partner(s) receiving the distribution which caused such adjustment.
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Samples: Petro Holdings Financial Corp
Basis Adjustments. To the extent an adjustment to the ----------------- adjusted tax basis of any Partnership asset pursuant to Code Section 734 (b734(b) or Code Section 743 (b743(b) is required under Regulation Section 1. 704 -1(b) (2)(iv)(m1.704-1(b)(2)(iv)(m) to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment. adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Regulations; provided, however, in the event that an adjustment to the Book Value of Partnership property is made as a result of an adjustment pursuant to Section 734 (b) of the Code, items of income, gain, loss or deduction, as computed for book and tax purposes, shall be specially allocated among the Partners so that the effect of any such adjustment shall benefit (or be borne by) the Partner(s) receiving the distribution which caused such adjustment.
Appears in 1 contract
Basis Adjustments. To the extent an adjustment to the ----------------- adjusted tax basis of any Partnership asset pursuant to Code Section 734 (b) or Code Section 743 (b) is required under Regulation Section 1. 704 -1(b1.704-1(b) (2)(iv)(m) to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment. increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Regulations; provided, however, in the event that an adjustment to the Book Value of Partnership property is made as a result of an adjustment pursuant to Section 734 (b) of the Code, items of income, gain, loss or deduction, as computed for book and tax purposes, shall be specially allocated among the Partners so that the effect of any such adjustment shall benefit (or be borne by) the Partner(s) receiving the distribution which caused such adjustment.
Appears in 1 contract
Samples: Limited Partnership Agreement (Petro Stopping Centers L P)
Basis Adjustments. To the extent an adjustment to the ----------------- adjusted tax basis of any Partnership Company asset pursuant to Code Section 734 (b734(b) or Code Section 743 (b743(b) is required under Treasury Regulation Section 1. 704 -1(b) (2)(iv)(m1.704-1(b)(2)(iv)(m) to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment. adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations; provided, however, in the event that an adjustment to the Book Value book value of Partnership Company property is made as a result of an adjustment pursuant to Section 734 (b734(b) of the Code, items of income, gain, loss loss, or deduction, as computed for book and tax purposes, shall be specially allocated among the Partners Members so that the effect of any such adjustment shall benefit (or be borne by) the Partner(sMember(s) receiving the distribution which caused such adjustment.
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Samples: Limited Liability Company Agreement (Apollo Management Holdings GP, LLC)
Basis Adjustments. To the extent an adjustment to the ----------------- adjusted tax basis of any Partnership Company asset pursuant to Code Section 734 (b734(b) or Code Section 743 (b743(b) is required under Regulation Treasury Regulations Section 1. 704 -1(b) (2)(iv)(m1.704-1(b)(2)(iv)(m) to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment. adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners Members in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations; provided, however, in the event that an adjustment to the Book Value of Partnership Company property is made as a result of an adjustment pursuant to Section 734 (b734(b) of the Code, items of income, gain, loss or deduction, as computed for book and tax purposes, shall be specially allocated among the Partners Members so that the effect of any such adjustment shall benefit (or be borne by) the Partner(sMember(s) receiving the distribution which caused such adjustment.
Appears in 1 contract
Samples: Operating Agreement (Integrated Health Services Inc)
Basis Adjustments. To the extent an adjustment to the ----------------- adjusted tax basis of any Partnership asset pursuant to Code Section 734 (b734(b) or Code Section 743 (b743(b) is required under Regulation Section 1. 704 -1(b) (2)(iv)(m1.704-1(b)(2)(iv)(m) to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment. adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Regulations; provided, however, in the event that an adjustment to the Book Value of -------- ------- Partnership property is made as a result of an adjustment pursuant to Section 734 (b734(b) of the Code, items of income, gain, loss or deduction, as computed for book and tax purposes, shall be specially allocated among the Partners so that the effect of any such adjustment shall benefit (or be borne by) the Partner(s) receiving the distribution which caused such adjustment.
Appears in 1 contract
Samples: Limited Partnership Agreement (Petro Stopping Centers L P)