Common use of Certain Contributions of Property Clause in Contracts

Certain Contributions of Property. In the event there is a difference between the Book Value at which any property is accepted as a contribution to the capital of the Company (or deemed accepted pursuant to Regulation Section 1.704-1 (b)(2)(iv)(g)) and the adjusted tax basis of such property to the Company, the Board of Managers shall, solely for federal income tax purposes (and not for purposes of allocating Net Profit or Net Loss under Section 7.6 or computing Net Profit or Net Loss), specially allocate the income, gain, loss and deduction attributable to such property to the extent required by Section 704(c) of the Code or any applicable Regulations under Code Section 704(b) or 704(c) using the traditional method under Regulation Section 1.704-3(b).

Certain Contributions of Property. In the event there is a ------------------------------------ difference between the Book Value at which any property is accepted as a contribution to the capital of the Company (or deemed accepted pursuant to Regulation Section 1.704-1 (b)(2)(iv)(g)) and the adjusted tax basis of such property to the Company, the Board of Managers shall, solely for federal income tax purposes (and not for purposes of allocating Net Profit or Net Loss under Section 7.6 or computing Net Profit or Net Loss), ------------ specially allocate the income, gain, loss and deduction attributable to such property to the extent required by Section 704(c) of the Code or any applicable Regulations under Code Section 704(b) or 704(c) using the traditional method under Regulation Section 1.704-3(b).