Characterization for Tax Purposes. For United States federal and state income tax purposes, the Depositor's contribution of the Receivables to the Trust in exchange for interests in the Trust, and the sale by the Depositor of Class A Certificates (which includes Class A-1 Certificates, Class A-2 Certificates and Class A-3 Certificates) and Class I Certificates and the retention by the Depositor of the Class IC Certificate is intended to constitute the formation of a partnership (the "Tax Partnership") whose partners are the Class A Certificateholders, the Class I Certificateholders and the Class IC Certificateholder (which are hereinafter collectively referred to as the "Tax Partners"). This Tax Partnership shall continue in effect as provided in Paragraph 3 below. The Tax Partnership shall not be a partnership to any other extent or for any other purpose.
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Samples: Pooling and Servicing Agreement (Uacsc 1997-C Auto Trust), Pooling and Servicing Agreement (Uacsc 1997-a Auto Trust), Pooling and Servicing Agreement (Uacsc 1997-B Auto Trust)
