Capital Account Matters. Upon the forfeiture or repurchase of a Vested Unit, the Capital Account associated with such Unit shall be apportioned among the Members, pro-rata in proportion to their then-Percentage Interests.
Capital Account Matters. To the extent necessary to comply with Section 704 of the Code and the Treasury Regulations thereunder, as determined by the Management Member, an administrative adjustment request or amended returns, as applicable, may be filed with respect to prior open years, such that, to the extent possible, the Capital Account of each Member, immediately prior to the final liquidating distribution (or final distributions if there will be more than one liquidating distribution), is equal to the amount which such Member is entitled to receive pursuant to such final liquidating distribution(s) under Section 9.2.
