Consent to Treatment for Tax Purposes. Each Holder of a Unit, by its acceptance thereof, covenants and agrees to treat itself as the owner, for United States federal, state and local income and franchise tax purposes, of (i) the related Preferred Securities or the appropriate Treasury Consideration, in the case of the Normal Units, or (ii) the Treasury Securities, in the case of the Stripped Units. Each Holder of Normal Units, by its acceptance thereof, further covenants and agrees to treat the Preferred Securities as indebtedness of the Company for United States federal, state and local income and franchise tax purposes. ARTICLE V
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Consent to Treatment for Tax Purposes. Each Holder of a Normal Unit or a Stripped Unit, by its acceptance thereof, covenants and agrees to treat itself as the owner, for United States federal, state and local income and franchise tax purposes, purposes of (i) the related Preferred Securities Notes or the appropriate Treasury Consideration, in the case of the Normal Units, or (ii) the Treasury Securities, in the case of the Stripped Units. Each Holder of a Normal UnitsUnit, by its acceptance thereof, further covenants and agrees (i) to treat the Preferred Securities Notes as indebtedness of the Company for United States federal, state and local income and franchise tax purposes. ARTICLE Vpurposes and (ii) to allocate 100.00% of the issue price of a Normal Unit to the beneficial interest in the Note and 0.00% of the issue price to the Purchase Contract.
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Consent to Treatment for Tax Purposes. Each Holder of a Normal Unit or a Stripped Unit, by its acceptance thereof, covenants and agrees to treat itself as the owner, for United States federal, state and local income and franchise tax purposes, purposes of (i) the related Preferred Securities Notes or the appropriate Treasury Consideration, in the case of the Normal Units, or (ii) the Treasury Securities, in the case of the Stripped Units. Each Holder of a Normal UnitsUnit, by its acceptance thereof, further covenants and agrees (i) to treat the Preferred Securities Notes as indebtedness of the Company for United States federal, state and local income and franchise tax purposes. ARTICLE Vpurposes and (ii) to allocate [ ]% of the issue price of a Normal Unit to the beneficial interest in the Note and [ ]% of the issue price to the Purchase Contract.
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Consent to Treatment for Tax Purposes. Each Holder of a Normal Unit or a Stripped Unit, by its acceptance thereof, covenants and agrees to treat itself as the owner, for United States federal, state and local income and franchise tax purposes, purposes of (i) the related Preferred Securities Notes or the appropriate Treasury Consideration, in the case of the Normal Units, or (ii) the Treasury Securities, in the case of the Stripped Units. Each Holder of a Normal UnitsUnit, by its acceptance thereof, further covenants and agrees (i) to treat the Preferred Securities Notes as indebtedness of the Company for United States federal, state and local income and franchise tax purposespurposes and (ii) to allocate 100% of the issue price of a Normal Unit to the beneficial interest in the Note and 0.00% of the issue price to the Purchase Contract. ARTICLE VTable of Contents
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Consent to Treatment for Tax Purposes. Each Holder of a Normal Unit or a Stripped Unit, by its acceptance thereof, covenants and agrees to treat itself as the owner, for United States federal, state and local income and franchise tax purposes, purposes of (i) the related Preferred Securities Notes or the appropriate Treasury Consideration, in the case of the Normal Units, or (ii) the Treasury Securities, in the case of the Stripped Units. Each Holder of a Normal UnitsUnit, by its acceptance thereof, further covenants and agrees (i) to treat the Preferred Securities Notes as indebtedness of the Company for United States federal, state and local income and franchise tax purposes. ARTICLE Vpurposes and (ii) to allocate [__]% of the issue price of a Normal Unit to the beneficial interest in the Note and [__]% of the issue price to the Purchase Contract.
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