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 Section 734(b) or Code Section 743(b) is required to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increased 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 a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section 1.704-1(b)(2)(iv)(m) of the Regulations.

Appears in 3 contracts

Samples: Limited Partnership Agreement (BPK Resources Inc), Limited Partnership Agreement (International Travel Cd S Inc), Limited Partnership Agreement (BPK Resources Inc)

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Code Section 754 Adjustment. To the extent an adjustment to --------------------------- the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required to be taken into account in determining Capital AccountsAccounts pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increased the basis of the assetis an increase) or loss (if the adjustment decreases such basis) is a decrease), and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Regulations Section 1.704-1(b)(2)(iv)(m) of the Regulations).

Appears in 1 contract

Samples: Omnibus Agreement (Unwired Telecom Corp)

Code Section 754 Adjustment. To the extent an adjustment to ------------------------------ the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increased 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 a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section 1.7041 .704-1(b)(2)(iv)(m) of the Regulations.

Appears in 1 contract

Samples: Limited Partnership Agreement (North American Natural Gas Inc)

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required to be taken into account in determining Capital AccountsAccounts pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increased the basis of the assetis an increase) or loss (if the adjustment decreases such basis) is a decrease), and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Regulations Section 1.704-1(b)(2)(iv)(m) of the Regulations).

Appears in 1 contract

Samples: Partnership Agreement (Texas Unwired)

Code Section 754 Adjustment. To the extent an adjustment to ------------------------------ the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increased 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 a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section 1.704l.704-1(b)(2)(iv)(ml(b)(2)(iv)(m) of the Regulations.

Appears in 1 contract

Samples: Limited Partnership Agreement (North American Natural Gas Inc)

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Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b734 (b) or Code Section 743(b743 (b) is required required, pursuant to Treasury Regulation Section 1.704-1(b) (2) (iv) (m) to be taken into account in determining Capital Accountscapital, accounts, the amount of such adjustment to the Capital Accounts capital accounts shall be treated as an item of gain (if the adjustment increased 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 a manner consistent with the manner in which their Capital Accounts capital accounts are required to be adjusted pursuant to such Section 1.704-1(b)(2)(iv)(m) of the Treasury Regulations.

Appears in 1 contract

Samples: Limited Partnership Agreement (Pepco Holdings Inc)

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accountscapital accounts, the amount of such adjustment to the Capital Accounts capital accounts shall be treated as an item of gain (if the adjustment increased 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 a manner consistent with the manner in which their Capital Accounts capital accounts are required to be adjusted pursuant to such Section 1.704-1(b)(2)(iv)(m) of the Treasury Regulations.

Appears in 1 contract

Samples: General Partnership Agreement (Pepco Holdings Inc)

Code Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any a Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m), to be taken into account in determining Capital Accountscapital accounts, the amount of such adjustment to the Capital Accounts capital accounts shall be treated as an item of gain (if the adjustment increased 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 a manner consistent with the manner in which their Capital Accounts capital accounts are required to be adjusted pursuant to such Section 1.704-1(b)(2)(iv)(m) of the Regulations.

Appears in 1 contract

Samples: Agreement of Limited Partnership (Noco Management LTD)

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