Contributed/Revalued Property. If any property is contributed to the Fund in kind, or if the Book Value of any Fund property is adjusted pursuant to applicable Treasury Regulations under Section 704(b) of the Code and this Agreement, all income, gain, loss and deduction with respect to such contributed or revalued property shall, solely for income tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Fund for Federal income tax purposes and its initial or revalued Book Value, in accordance with Treasury Regulation § 1.704-1(b)(4)(i), Section 704(c) of the Code and the Regulations thereunder. Allocations pursuant to this Section 5.3(b) are solely for purposes of Federal and state income taxes and shall not affect, or in any way be taken into account in computing, any Member’s Capital Account or share of Net Income, Net Loss, or Distributions pursuant to any provision of this Agreement.
Contributed/Revalued Property. If any property is contributed to the Partnership in kind, or if the Book Value of any Partnership property is adjusted pursuant to applicable Regulations under section 704(b) of the Code and this Agreement, all income, gain, loss and deduction with respect to such contributed or revalued property shall, solely for tax purposes, be allocated among the Partners so as to take account of any variation between the adjusted basis of such property to the Partnership for federal income tax purposes and its initial or revalued Book Value, in such manner as the General Partner may determine in accordance with section 704(c) of the Code, the Treasury Regulations promulgated thereunder and Treasury Regulation Section 1.704-1(b)(4)(i). Allocations pursuant to this Section 5.05(f) are solely for purposes of federal and state taxes and shall not affect, or in any way be taken into account in computing, any Partner's Capital Account or share of Profit, Loss or distributions pursuant to any provision of this Agreement.
Contributed/Revalued Property. If any property is contributed to the Partnership in kind, or if the Book Value of any Partnership property is adjusted pursuant to applicable Regulations under section 704(b) of the Code and this Agreement, all income, gain, loss and deduction with respect to such contributed or revalued property shall, solely for tax purposes, be allocated among the Partners so as to take account of any variation between the adjusted basis of such property to the Partnership for federal income tax purposes and its initial or revalued Book Value, in accordance with section 704(c) of the Code and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the General Partner in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 6.7 are solely for purposes of federal and state taxes and shall not affect, or in any way be taken into account in computing Net Income or Loss, any Partner’s Capital Account or the manner in which distributions are made pursuant to any provision of this Agreement.
