Character of Liquidating Distributions. All payments made in liquidation of the interest of a Unit Holder in the Company shall be made in exchange for the interest of such Unit Holder in Property pursuant to Section 736(b)(1) of the Code, including the interest of such Unit Holder in Company goodwill.
Character of Liquidating Distributions. All payments made in liquidation of the interest of a Member in the Company shall be made in exchange for the interest of such Member in Properties pursuant to Section 736(b)(l) of the Code, including the interest of such Member in the goodwill of the Company.
Character of Liquidating Distributions. All payments made in liquidation of the Interest of a retiring Partner shall be made in exchange for the interest of such Partner in Partnership property pursuant to Section 736(b)(1) of the Code, including the interest of such Partner in Partnership goodwill.
Character of Liquidating Distributions. 43 Section 13.9 The Liquidator............................................................................. 43 Section 13.10 Form of Liquidating Distributions......................................................... 43
Character of Liquidating Distributions. All payments made in liquidation of the Interest of a retiring Member, other than payments made under Section 12.2, shall be made in exchange for the interest of such Member in Company Property pursuant to Code § 736(b)(1), including the interest of such Member in goodwill of the Company.
Character of Liquidating Distributions. Except as otherwise required by the I.R.C., amounts paid to Members pursuant to this Section 14.4 shall be treated as made in exchange for the interest of the Member in Company property pursuant to I.R.C. Section 736(b)(1), including the interest of such Member in Company goodwill.
Character of Liquidating Distributions. 36 ARTICLE XII
Character of Liquidating Distributions. To the extent that the tax treatment of any payments or distributions to any Management Unit Holder pursuant to this Agreement is governed by Section 736 of the Code, such payments or distributions shall be treated as made in exchange for such Member’s interests in the Company’s property pursuant to Section 736(b)(1) of the Code, including the interests of such Management Unit Holder in the Company’s goodwill.
Character of Liquidating Distributions. 45 PAGE ---- SECTION 13.06. Indemnification of the Liquidator .............................. 45
Character of Liquidating Distributions. All payments made in liquidation of the interest of a Member in Company shall be made in exchange for the interest of such Member in Company Property pursuant to Section 736(b)(1) of the Code, including the interest of such Member in Company goodwill.
