Common use of Disallowance of Deductions Clause in Contracts

Disallowance of Deductions. Notwithstanding any other provisions of this Agreement, in the event that any fees paid to the General Partner or its affiliates pursuant to this Agreement or any Schedule hereto, and deducted by the Partnership in reliance on Section 707(a) and/or 707(c) of the Internal Revenue Code of 1986, as amended (Code) are disallowed as deductions to the Partnership on its federal income tax return and treated as Partnership distributions, the General Partner shall be allocated items of Partnership income, if any, in the year such fees were paid, equal to the amount of such fees for which deductions were disallowed. In such event, the amounts paid to the General Partner shall be deemed to be partnership distributions and not fee payments.

Disallowance of Deductions. Notwithstanding any other provisions of this Agreement, in the event that any fees amounts paid to the General Partner or its affiliates pursuant to this Agreement or on any Schedule Exhibit hereto, and deducted by the Partnership in reliance on Section 707(a) and/or 707(c) of the Internal Revenue Code of 1986, as amended ("Internal Revenue Code") are disallowed as deductions to the Partnership on its federal income tax return and treated as Partnership distributions, the General Partner shall be allocated items of Partnership income, if any, in the year such fees were paid, equal to the amount of such fees amounts for which deductions were disallowed. In such event, the amounts paid to the General Partner shall be deemed to be partnership distributions and not fee payments.

Disallowance of Deductions. Notwithstanding any other provisions of this Agreement, in the event that any fees amounts paid to the General Partner or its affiliates pursuant to this Agreement or any Schedule hereto, and deducted by the Partnership in reliance on Section 707(a) and/or 707(c) of the Internal Revenue Code of 1986, as amended (Code) are disallowed as deductions to the Partnership on its federal income tax return and treated as Partnership distributions, the General Partner shall be allocated items of Partnership income, if any, in the year such fees were paid, equal to the amount of such fees amounts for which deductions were disallowed. In such event, the amounts paid to the General Partner shall be deemed to be partnership distributions and not fee payments.