Common use of Certain Section 754 Adjustments Clause in Contracts

Certain Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 743(b), Code Section 732(d) or Code Section 734(b) is required to be taken into account in determining Capital Accounts as the result of a distribution to a Partner in complete liquidation of its interest in the Partnership, pursuant to Regulations (S) 1.704-1(b)(2)(iv)(m), the amount of such adjustment to 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 accordance with their interests in the Partnership as determined under Regulations 1.704-1(b)(3) in the event Regulations (S) 1.704- 1(b)(2)(iv)(m)(2) applies, or to the Partner to whom such distribution was made in the event Regulations (S) 1.704-1(b)(2)(iv)(m)(4) applies.

Certain Section 754 Adjustments. To the extent an any adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 743(b732(d), Code Section 732(d) or Code Section 734(b) or Section 743(b) of the Code is required required, pursuant to Treas. Reg. Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts as the result of a distribution to a Partner in complete liquidation of its interest in the Partnership, pursuant to Regulations (S) 1.704-1(b)(2)(iv)(m), the amount of such adjustment to Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis such basis) and an item of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in accordance with their interests in the Partnership as determined under Treasury Regulations Section 1.704-1(b)(3) in the event Treasury Regulations (S) 1.704- Section 1.704-1(b)(2)(iv)(m)(2) applies, or to the Partner to whom such distribution was made in the event Treasury Regulations (S) Section 1.704-1(b)(2)(iv)(m)(4l(b)(2)(iv)(m)(4) applies.