Common use of Code Section 754 Adjustment Clause in Contracts

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Sections 734(b) or 743(b) is required pursuant to Treasury Regulations Sections 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as a result of a distribution to a Partner in complete liquidation of its interest in the Partnership, 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 losses (if the adjustment decreases such basis) and such gain or losses shall be specifically allocated to the Partners in accordance with their interests in the Partnership (in the event Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies) or to the Partners to whom such distribution was made (in the event Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies).

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset pursuant to Code Sections Section 734(b) or Section 743(b) of the Code is required required, pursuant to Treasury Regulations Sections Regulation Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as a the result of a distribution to a Partner Member in complete liquidation of its his interest in the PartnershipCompany, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or losses loss (if the adjustment decreases such basis) and such gain or losses loss shall be specifically specially allocated to the Partners Members in accordance with their interests in the Partnership (Company in the event Treasury Regulations Regulation Section 1.704-1(b)(2)(iv)(m)(2) applies) , or to the Partners Member to whom such distribution was made (in the event Treasury Regulations Regulation Section 1.704-1(b)(2)(iv)(m)(4) applies).

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulations Sections Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4)) of the Regulations, to be taken into account in determining Capital Accounts as a the result of a distribution to a Partner Member in complete liquidation of its interest Membership Interest in the PartnershipCompany, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or losses loss (if the adjustment decreases such basis) and such gain or losses loss shall be specifically specially allocated to the Partners Members in accordance with their interests in the Partnership (Company in the event Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(2) of the Regulations applies) , or to the Partners Member to whom such distribution was made (in the event Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(4) of the Regulations applies).

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis asis of any Partnership Company asset pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulations Sections Section 1.704-1(b)(2)(iv)(m)(2) or 1.704-Treasury Regulations Section 1.704- 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as a result of a distribution to a Partner Member in complete liquidation of its interest in the Partnershiphis interest, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or losses loss (if the adjustment decreases such basis) and such gain or losses loss shall be specifically allocated to the Partners Members in accordance with their interests in the Partnership (Company in the event Treasury Regulations Section 1.704-1.704- 1(b)(2)(iv)(m)(2) applies) , or to the Partners Members to whom such distribution was made (in the event that Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies).

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulations Sections Regulation Section 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4Regulations Section 1.704.1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as a the result of a distribution to a Partner in complete liquidation of its interest in the Partnershipsuch Partner's Partnership Interest, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or losses loss (if the adjustment decreases such basis) and such gain or losses loss shall be specifically specially allocated to the Partners in accordance with their interests in the Partnership (Percentage Interests in the event Treasury Regulations Regulation Section 1.704-1(b)(2)(iv)(m)(2) applies) , or to the Partners to whom such distribution was made (in the event Treasury Regulations Regulation Section 1.704-1(b)(2)(iv)(m)(4) applies).

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership asset Company asset, pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulations Sections Section 1.704-1(b)(2)(iv)(m)(2l(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4)l(b)(2)(iv)(m)(4) of the Regulations, to be taken into account in determining Capital Accounts as a the result of a distribution to a Partner Member in complete liquidation of its interest in the Partnershipsuch Member's Interest, 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 losses loss (if the adjustment decreases such basis) and such gain or losses loss shall be specifically specially allocated to the Partners Members in accordance with their interests in the Partnership (Company in the event Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(2l(b)(2)(iv)(m)(2) of the Regulations applies) , or to the Partners Member to whom such distribution was made (in the event Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(4l(b)(2)(iv)(m)(4) of the Regulations applies).

Code Section 754 Adjustment. To the extent that an adjustment to the adjusted tax basis of any Partnership Company asset pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulations Sections Section 1.704-1(b)(2)(iv)(m)(2) or Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as a result of a distribution to a Partner Member in complete liquidation of its interest in the Partnershipsuch Member’s interest, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or losses loss (if the adjustment decreases such basis) ), and such gain or losses loss shall be specifically allocated to the Partners Members in accordance with their interests in the Partnership (Company in the event that Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies) applies or to the Partners Members to whom such distribution was made (in the event that Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies).

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership Company asset pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulations Sections Section 1.704-1(b)(2)(iv)(m)(2l(b)(2)(iv)3(m)(2) or Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(4l(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as a result of a distribution to a Partner Member in complete liquidation of its interest in the Partnershiphis interest, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or losses loss (if the adjustment decreases such basis) and such gain or losses loss shall be specifically allocated to the Partners Members in accordance with their interests in the Partnership (Company in the event Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(2) applies) , or to the Partners Members to whom such distribution was made (in the event that Treasury Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies).

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Sections Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulations Sections Regulation Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as a result of a distribution to a Partner in complete liquidation of its interest in the Partnershipinterest, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or losses loss (if the adjustment decreases such basis) and such gain or losses loss shall be specifically allocated to the Partners in accordance with their interests in the Partnership (in the event if Treasury Regulations Regulation Section 1.704-1(b)(2)(iv)(m)(2) applies) , or to the Partners to whom such distribution was made (in the event if Treasury Regulations Regulation Section 1.704-1(b)(2)(iv)(m)(4) applies).