Common use of Distributive Share for Federal Income Tax Purposes Clause in Contracts

Distributive Share for Federal Income Tax Purposes. The Partnership shall report each Partner’s distributive share of Net Profits, Net Losses and items of income, gain, loss and deduction in accordance with the rules of Section 704(b) and (c) of the Code, as determined by the General Partner upon the advice of the Partnership’s accountants and/or tax counsel. Except as otherwise provided herein, each Partner’s share of each item of Partnership income, gain, loss or deduction for each taxable period shall equal such Partner’s share of Net Profits or Net Losses for such period. For Federal income tax purposes, the Partnership shall use the “remedial allocation method,” as described in Treas. Reg. §1.704-3(d), to allocate income, gain, loss or deduction with respect to any property contributed by a Partner to the Partnership and with respect to any property for which differences between book value and adjusted tax basis are created pursuant to Section 7(l). These allocations shall not affect the Partner’s Capital Account.

Distributive Share for Federal Income Tax Purposes. The Partnership shall report each Partner’s distributive share of Net Profits, Net Losses and items of income, gain, loss and deduction in accordance with the rules of Section 704(b) and (c) of the CodeC6de, as determined by the General Partner upon the advice of the Partnership’s accountants and/or tax counsel. Except as otherwise provided herein, each Partner’s share of each item of Partnership income, gain, loss or deduction for each taxable period shall equal such Partner’s share of Net Profits or Net Losses for such period. For Federal income tax purposes, the Partnership shall use the “remedial allocation method,” as described in Treas. Reg. §1.704-3(d), to allocate income, gain, loss or deduction with respect to any property contributed by a Partner to the Partnership and with respect to any property for which differences between book value and adjusted tax basis are created pursuant to Section 7(l7(k). These allocations shall not affect the Partner’s Capital Account.