CONSISTENCY WITH ALLOCATION RULES. Notwithstanding the terms of Section 3.1, allocations of items described therein shall be made to the Partners in the manner required by Treasury Regulations sections 1.704-1(b) and 1.704-2 in order for the allocations described in Section 3.1 to be respected for U.S. Federal income tax purposes.
Appears in 7 contracts
Sources: Agreement of Limited Partnership (NRG Retail LLC), Limited Partnership Agreement (Delta Energy Center, LLC), Limited Partnership Agreement (Delta Energy Center, LLC)
CONSISTENCY WITH ALLOCATION RULES. Notwithstanding the terms of Section 3.1, allocations of items described therein shall be made to the Partners in the manner required by Treasury Regulations sections 1.704-1(b1 (b) and 1.704-2 in order for the allocations described in Section 3.1 to be respected for U.S. Federal income tax purposes.
Appears in 3 contracts
Sources: Limited Partnership Agreement (Delta Energy Center, LLC), Limited Partnership Agreement (Delta Energy Center, LLC), Limited Partnership Agreement (Delta Energy Center, LLC)
CONSISTENCY WITH ALLOCATION RULES. Notwithstanding the terms of Section 3.1, allocations of items described therein shall be made to the Partners in the manner required by Treasury Regulations sections 1.704-1(bl(b) and 1.704-2 in order for the allocations described in Section 3.1 to be respected for U.S. Federal income tax purposes.
Appears in 1 contract
CONSISTENCY WITH ALLOCATION RULES. Notwithstanding the terms of Section 3.1, allocations of items described therein shall be made to the Partners in the manner required by Treasury treasury Regulations sections 1.704-1(b) and 1.704-2 in order for the allocations described in Section 3.1 to be respected for U.S. Federal income tax fax purposes.
Appears in 1 contract
Sources: Limited Partnership Agreement (Delta Energy Center, LLC)