Contributed Property. All items of gain, loss and deduction with -------------------- respect to property that is reflected in the Capital Accounts of the Members at a basis different from such property's adjusted tax basis will be allocated, solely for tax purposes, among the Members to take into account the variation between the adjusted tax basis of the property and the basis reflected in the Member's Capital Account according to the principles of the (S) 704(c)
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Samples: Operating Agreement (FLN Finance Inc), Operating Agreement (FLN Finance Inc), Operating Agreement (FLN Finance Inc)
Contributed Property. All items of gain, loss and deduction with -------------------- respect to property that is reflected in the Capital Accounts of the Members at a basis different from such property's adjusted tax basis will be allocatedwill, solely for tax purposes, be allocated among the Members so as to take into account the variation between the adjusted tax basis of the property and the basis reflected in the Member's Capital Account according to the principles of the (S) 704(css.704(c)
Appears in 1 contract
Contributed Property. All items of gain, loss and deduction with -------------------- respect to property that is reflected in the Capital Accounts of the Members at a basis different from such property's adjusted tax basis will be allocated, solely for tax purposes, among the Members to take into account the variation between the adjusted tax basis of the property and the basis reflected in the Member's Capital Account according to the principles of the (S) ss. 704(c)
Appears in 1 contract
Samples: Reorganization Agreement (General Communication Inc)