Contributions of Property. In the event that property (other than cash) is contributed by a Shareholder to the Trust, the computation of Capital Accounts, as set forth in this Section 9.4, shall be adjusted as follows:
(i) the contributing Shareholder's Capital Account shall be increased by the fair market value of the property contributed to the Trust by such Shareholder (net of liabilities securing such contributed property that the Trust is considered to assume or take subject to under Code Section 752); and
Contributions of Property. In accordance with IRC Section ------------------------- 704(c) and the Treasury Regulations thereunder, solely for federal and applicable state and local income tax purposes, income, gain, loss and deduction with respect to any property contributed to the Partnership shall be allocated among the Partners so as to take account of any variation between the adjusted basis of such property to the contributing Partner for federal income tax purposes and its fair market value at the time of contributions.
Contributions of Property. The Partners agree that the fair market value of the property contributed pursuant to Section 6.2 shall be as set forth in Appendix B hereto.
Contributions of Property. In accordance with Section 704(c) of the Code and the Treasury Regulations thereunder, depreciation, amortization, gain and loss, as determined for tax purposes, with respect to any contributed property the book value of which differs from its adjusted basis for federal income tax purposes, shall, for tax purposes, be allocated between the Members so as to take account of any variation between the adjusted basis of such property to the LLC for federal income tax purposes and its book value. Allocations pursuant to this Section 6.5(c) are solely for purposes of federal, state and local taxes and shall not affect, or in any way be taken into account in computing, the capital account of any Member or such Member's share of profit, loss, other items, or distributions pursuant to any provision of this Agreement. The provisions of this Section 6.5(c) relating to federal income tax treatment of an item shall apply for state and local income tax purposes to the extent permitted under applicable law. Any elections or other decisions relating to such allocations shall be made by the Board of Representatives pursuant to Section 7.1(e) of this Agreement.
Contributions of Property. In the event that property (other than cash) is contributed (or deemed contributed pursuant to the provisions of Code Section 708) by a Shareholder to the Trust, including the contribution of a Shareholder's interest in Summit Tax Exempt Bond Fund, L.P., Summit Tax Exempt L.P. II, and/or Summit Tax Exempt L.P. XXX xx the Trust pursuant to the Solicitation Statement (the "Consolidation Contribution"), the computation of Capital Accounts, as set forth in this Section 9.4, shall be adjusted as follows:
(i) the contributing Shareholder's Capital Account shall be increased by the fair market value of the property contributed to the Trust by such Shareholder (net of liabilities securing such contributed property that the Trust is considered to assume or take subject to under Code Section 752); and
Contributions of Property. In the event that property (other than cash) is contributed by a Shareholder to the Trust, the computation of Capital Accounts, as set forth in this Section 9.4, shall be adjusted as follows:
(i) the contributing Shareholder's Capital Account shall be increased by the fair market value of the property contributed to the Trust by the Shareholder (net of liabilities securing such contributed property that the Trust is considered to assume or take subject to under Section 752 of the Code); and
(ii) as and if required by Treas. Reg. xx.xx. 1.704-l(b)(2)(iv)(g) and 1.704-l(b)(4)(i), if a Shareholder's Capital Account reflects a fair market value for property which differs from such property's adjusted basis, such Shareholder's Capital Account thereafter shall be adjusted to take account of the amount of Book Gain and Book Loss allocated to such Shareholder pursuant to Section 9.5 hereof and shall not thereafter take into account the net income, net gain and net loss for tax purposes allocated to such Shareholder pursuant to this Article 9.
Contributions of Property. In accordance with Section 704(c) of the Code and the Treasury Regulations thereunder, depreciation, amortization, gain and loss, as determined for tax purposes, with respect to any contributed property the book value of which differs from its adjusted basis for federal income tax purposes, shall, for tax purposes, be allocated between the Members so as to take account of any variation between the adjusted basis of such property to the LLC for federal income tax purposes and its book value.
Contributions of Property. The following Members shall contribute to the capital of the Company the property and assets described for each respective member on Exhibit 2.b, attached to this Agreement and made a part hereof by this reference with the respective values shown opposite their names, as follows:
Contributions of Property. The parties of this Agreement presently own certain fire protection, emergency response and emergency medical services facilities, vehicles and equipment. These facilities, vehicles and equipment shall be titled, deeded or otherwise conveyed to the Agency. A monetary value shall be established for such facilities and equipment before they are conveyed to the Agency.
Contributions of Property. If property other than cash is contributed or deemed contributed by a Member to the Company, the following special rules shall apply:
(a) The increase in the Member's capital account shall be the fair market value of the property contributed, net of liabilities secured by the property that the Company assumes or is considered to assume, or subject to which the property is taken.
(b) The Members' capital accounts shall be adjusted as required under Treasury Regulations Sections 1.704-1(b)(2)(iv)(g) and Section 1.704-1(b)(4)(i), to account for differences between the book value and fair market value of the property.
