Company Nonrecourse Deductions. Loss attributable (under Treasury Regulation Section 1.704-2(c)) to “partnership nonrecourse liabilities” (within the meaning of Treasury Regulation Section 1.704-2(b)(1)) shall be allocated among the Members in the same proportion as their respective Percentage Interests.
Appears in 4 contracts
Samples: Operating Agreement (PJC Manchester Realty LLC), Operating Agreement (PJC Manchester Realty LLC), Operating Agreement (PJC Manchester Realty LLC)
Company Nonrecourse Deductions. Loss attributable (under Treasury Regulation Section 1.704-2(c)) to “"partnership nonrecourse liabilities” " (within the meaning of Treasury Regulation Section 1.704-2(b)(1)) shall be allocated among the Members in the same proportion as their respective Percentage Interests.
Appears in 4 contracts
Samples: Operating Agreement (Crown Castle International Corp), Operating Agreement (Crown Castle International Corp), Operating Agreement (Bell Atlantic Corp)
Company Nonrecourse Deductions. Loss attributable (under Treasury Regulation Section 1.704-2(c)) to “partnership nonrecourse liabilities” ’ (within the meaning of Treasury Regulation Section 1.704-2(b)(1)) shall be allocated among the Members Partners in the same proportion as their respective Percentage Partnership Interests.
Appears in 2 contracts
Samples: Partnership Agreement, Partnership Agreement (Verizon Wireless Capital LLC)
Company Nonrecourse Deductions. Loss attributable (under ------------------------------ Treasury Regulation Section 1.704-2(c)) to “"partnership nonrecourse liabilities” " (within the meaning of Treasury Regulation Section 1.704-2(b)(1)) shall be allocated among the Members Partners in the same proportion as their respective Percentage Partnership Interests.
Appears in 1 contract
Samples: u.s. Wireless Alliance Agreement (Bell Atlantic Corp)
Company Nonrecourse Deductions. Loss attributable (under Treasury Regulation Section 1.704-2(c)) to “partnership nonrecourse liabilities” (within the meaning of Treasury Regulation Section 1.704-2(b)(1)) shall be allocated among the Members Partners in the same proportion as their respective Percentage Partnership Interests.
Appears in 1 contract
Samples: u.s. Wireless Alliance Agreement (Verizon Wireless Capital LLC)
Company Nonrecourse Deductions. Loss attributable (under Treasury Regulation Regulations Section 1.704-2(c)) to “"partnership nonrecourse liabilities” " (within the meaning of Treasury Regulation Regulations Section 1.704-2(b)(1)) shall be allocated among the Members in the same proportion as their respective Percentage Membership Interests.
Appears in 1 contract
Company Nonrecourse Deductions. Loss attributable (under Treasury Regulation Section 1.704-2(c)) to “partnership nonrecourse liabilities” (within the meaning of Treasury Regulation Section 1.704-2(b)(1)) shall be allocated among the Members in the same proportion as their respective Percentage Membership Interests.
Appears in 1 contract
Company Nonrecourse Deductions. Loss attributable (under Treasury Regulation Section 1.704-2(c)) to “"partnership nonrecourse liabilities” ' (within the meaning of Treasury Regulation Section 1.704-2(b)(1)) shall be allocated among the Members Partners in the same proportion as their respective Percentage Partnership Interests.
Appears in 1 contract