Common use of Capital Account Deficits Clause in Contracts

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General Partner in an amount necessary to offset the Loss previously allocated to the General Partner under this Section 5.01(e).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General each Partner under this Section 5.01(e).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e5.01(d).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner Member to the extent that such allocation would cause a deficit in such PartnerMember’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such PartnerMember’s shares of Partnership Company Minimum Gain and Partner Member Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partnerother Members. After the occurrence of an allocation of Loss to the General Partner other Members in accordance with this Section 5.01(e5.1(e), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General Partner other Members in an amount necessary to offset the Loss previously allocated to the General Partner other Members under this Section 5.01(e5.1(e).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General each Partner under this Section 5.01(e5.01(d).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e), to the extent permitted by Regulations Section 1.704-1(b), Profit shall first shall be allocated to the General Partner in an amount necessary to offset the Loss previously allocated to the General Partner under this Section 5.01(e).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General each Partner under this Section 5.01(e).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e), to the extent permitted by Regulations Section 1.704-1(b), -16- Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General each Partner under this Section 5.01(e).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General Partner in an amount necessary to offset the Loss previously allocated to the General Partner under this Section 5.01(e5.01(d).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss loss in excess of that limitation shall be allocated to the General Partnerother Partners who have positive Capital Account balances in accordance with their respective Percentage Interests. After the occurrence of an allocation of Loss loss to the General a Partner in accordance with this Section 5.01(e5.01(i), to the extent permitted by Regulations Section 1.704-1(b), Profit first profit, income, or gain shall be allocated to the General such Partner in an amount necessary to offset the Loss a loss previously allocated to the General such Partner under this Section 5.01(e5.01(i).

Capital Account Deficits. Loss shall not be allocated to a ------------------------ Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e5.01(d).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.1(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General Partner in an amount necessary to offset the Loss previously allocated to the General Partner under this Section 5.01(e5.1(d).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e5.01(d).

Capital Account Deficits. Loss shall not be allocated to a the Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section sections 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e)5.6, to the extent permitted by Regulations Section section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e)5.6.

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gainnonrecourse debt minimum gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.1(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General Partner in an amount necessary to offset the Loss previously allocated to the General Partner under this Section 5.01(e5.1(d).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e).

Capital Account Deficits. Residual Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Residual Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Residual Loss to the General Partner in accordance with this Section 5.01(e), to the extent permitted by Regulations Section 1.704-1(b), Current and Residual Profit first shall be allocated to the General such Partner in an amount necessary to offset the Residual Loss previously allocated to the General such Partner under this Section 5.01(e).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General each Partner under this Section 5.01(e5.01(d).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General Partner in an amount necessary to offset the Loss previously allocated to the General Partner under this Section 5.01(e).

Capital Account Deficits. Loss shall not be allocated to a Limited ------------------------ Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partnerother Partners in accordance with their respective Percentage Interests. After the occurrence of an allocation of Loss to the General a Partner in accordance with this Section 5.01(e5.01(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e5.01(d).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e)6.5, to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General Partner in an amount necessary to offset the Loss previously allocated to the General Partner under this Section 5.01(e)6.5.

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(f), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e5.01(f).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Non-recourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e5.01(d).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1.704- 1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e5.01(d).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Non recourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e5.01(d).

Capital Account Deficits. Loss shall not be allocated to a Limited ------------------------ Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General each Partner under this Section 5.01(e5.01(d).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Non-recourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e5.01(d).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.1(e), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General Partner in an amount necessary to offset the Loss previously allocated to the General Partner under this Section 5.01(e5.1(e).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.1(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e5.1(d).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4subparagraphs (4), (5) and (6) of Regulations Section 1.704-1(b)(2)(ii)(d)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General Partner in an amount necessary to offset the Loss previously allocated to the General Partner under this Section 5.01(e).

Capital Account Deficits. Loss shall not be allocated to a the Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section sections 1.704-1(b)(2)(ii)(d)(41(b)(2)(ii)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e)5.6, to the extent permitted by Regulations Section section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e)5.6.

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) ), and (6)) to exceed in excess of the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(b), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be specially allocated to the General Partner in an amount necessary to offset the Loss previously allocated to the General Partner under this Section 5.01(e5.01(b).

Capital Account Deficits. Loss shall not be allocated to a Limited ------------------------ Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Non-recourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e5.01(d).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4l(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.1(d), to the extent permitted by Regulations Section 1.704-1(bl(b), Profit shall first shall be allocated to the General Partner in an amount necessary to offset the Loss previously allocated to the General Partner under this Section 5.01(e5.1(d).

Capital Account Deficits. Loss shall not be allocated to a ------------------------ Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e5.01(d), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General each Partner under this Section 5.01(e5.01(d).

Capital Account Deficits. Loss shall not be allocated to a the ------------------------ Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Treasury Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e)5.6, to the extent permitted by Treasury Regulations Section 1.704-1(b), Profit first shall be allocated to the General such Partner in an amount necessary to offset the Loss previously allocated to the General such Partner under this Section 5.01(e)5.6.

Capital Account Deficits. Loss Losses shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4l(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss Losses in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss Losses to the General Partner in accordance with this Section 5.01(e5.01(g), to the extent permitted by Regulations Section 1.704-1(bl(b), Profit first Profits shall be allocated to the General such Partner in an amount necessary to offset the Loss Losses previously allocated to the General each Partner under this Section 5.01(e5.01(g).

Capital Account Deficits. Loss shall not be allocated to a Limited Partner to the extent that such allocation would cause a deficit in such Partner’s 's Capital Account (after reduction to reflect the items described in Regulations Section 1.704-1(b)(2)(ii)(d)(4), (5) and (6)) to exceed the sum of such Partner’s 's shares of Partnership Minimum Gain and Partner Nonrecourse Debt Minimum Gain. Any Loss in excess of that limitation shall be allocated to the General Partner. After the occurrence of an allocation of Loss to the General Partner in accordance with this Section 5.01(e), to the extent permitted by Regulations Section 1.704-1(b), Profit first shall be allocated to the General Partner in an amount necessary to offset the Loss previously allocated to the General Partner under this Section 5.01(e).