Common use of Capital Accounts Attributable to Class A and Class Clause in Contracts

Capital Accounts Attributable to Class A and Class. A-1 Common Units. Immediately following the Merger, each Limited Partner retained the portion of such Limited Partner’s Capital Account attributable to the Class A Common Units outstanding immediately prior to the Merger that were converted into Class A-1 Common Units in the Merger. Such Limited Partner’s Capital Account attributable to such Class A Common Units that were converted into Class A-1 Common Units in the Merger (and federal income tax basis and other tax attributes, including, without limitation, the debt allocations pursuant to Section 752 of the Code, to the extent permissible) shall not be affected by any future cancellation of such Class A-1 Common Units as provided in Section 3.1(d)(v); instead such portion of such Limited Partner’s Capital Account shall be allocated in its entirety to the portion of such Limited Partner’s Capital Account attributable to such Limited Partner’s Class A Common Units.