Common use of Considered a Partnership Clause in Contracts

Considered a Partnership. The Partners intend that, as defined in Section 7701(a) (2) of the Code, the Partnership will be treated as a partnership for United States, state and local income tax purposes. Specifically, each Partner agrees not to make the election described in Section 761(a) of the Code to be excluded from the application of the provisions of Subchapter K. Moreover, each Partner further agrees not to make an election to be excluded from the application of the partnership provisions of any applicable state taxation code or statute.

Appears in 2 contracts

Samples: Limited Partnership Agreement (Atlantic Oklahoma Wind, LLC), Limited Partnership Agreement (Atlantic Oklahoma Wind, LLC)

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Considered a Partnership. The Partners intend that, as defined in Section 7701(a) (2) pursuant to the provisions of Subchapter K of Chapter 1 of Subtitle A of the Internal Revenue Code of 198 6 (hereinafter referred to as "Code") , the Partnership will be treated as a partnership for United States, state and local income tax purposes. Specifically, each Partner agrees not to make the election described in an election, as permitted by Code Section 761(a) of the Code 761, to be excluded from the application of the provisions of Subchapter K. Moreover, each Each Partner further also agrees not to make an election to be excluded from give any notices or take any other action inconsistent with the application of the partnership provisions of any applicable state taxation code or statutePartnership election.

Appears in 1 contract

Samples: General Partnership Agreement (Bonneville Pacific Corp)

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Considered a Partnership. The Partners intend that, as defined in Section 7701(a) (27701(a)(2) of the Code, the Partnership will be treated as a partnership for United States, state and local income tax purposes. Specifically, each Partner agrees not to make the election described in Section 761(a) of the Code to be excluded from the application of the provisions of Subchapter K. Moreover, each Partner further agrees not to make an election to be excluded from the application of the partnership provisions of any applicable state taxation code or statute.

Appears in 1 contract

Samples: General Public Utilities Corp /Pa/

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