Elimination of Book/Tax Disparities. If any Partnership property has a Carrying Value on the books of the Partnership different from its adjusted tax basis to the Partnership for U.S. Federal income tax purposes (whether by reason of the contribution of such property to the Partnership or otherwise), allocations of taxable income, gain, loss and deduction under this Article 3 with respect to such asset shall take account of any variation between the adjusted tax basis of such asset for federal income tax purposes and its Carrying Value in the same manner as under Code section 704(c) or the principles set forth in Treasury Regulations section 1.704-1(b)(2)(iv)(g), as the case may be, using the remedial method set forth in Treasury Regulation section 1.704-3(d), unless each of the Partners otherwise agrees.
Appears in 7 contracts
Samples: Limited Partnership Agreement (Delta Energy Center, LLC), Limited Partnership Agreement (Delta Energy Center, LLC), Limited Partnership Agreement (Delta Energy Center, LLC)
Elimination of Book/Tax Disparities. If any Partnership property has a Carrying Value on the books of the Partnership different from its adjusted tax basis to the Partnership for U.S. Federal income tax purposes (whether by reason of the contribution of such property to the Partnership or otherwise), allocations of taxable income, gain, loss and deduction under this Article 3 with respect to such asset shall take account of any variation between the adjusted tax basis of such asset for federal income tax purposes and its Carrying Value in the same manner as under Code section 704(c) or the principles set forth in Treasury Regulations section 1.704-1(b)(2)(iv)(g1 (b)(2)(iv)(g), as the case may be, using the remedial method set forth in Treasury Regulation section 1.704-3(d), unless each of the Partners otherwise agrees.
Appears in 2 contracts
Samples: Agreement of Limited Partnership (NRG Retail LLC), Limited Partnership Agreement (Delta Energy Center, LLC)
Elimination of Book/Tax Disparities. If any Partnership property has a Carrying Value on the books of the Partnership different from its adjusted tax basis to the Partnership for U.S. Federal income tax purposes (whether by reason of the contribution of such property to the Partnership or otherwise), allocations of taxable income, gain, loss and deduction under this Article 3 with respect to such asset shall take account of any variation between the adjusted tax basis of such asset for federal income tax purposes and its Carrying Value in the same manner as under Code section 704(c) or the principles set forth in Treasury treasury Regulations section 1.704-1(b)(2)(iv)(g), as the case may be, . using the remedial method set forth in Treasury Regulation section 1.704-3(d), unless each of the Partners otherwise agrees.
Appears in 1 contract
Samples: Limited Partnership Agreement (Delta Energy Center, LLC)
Elimination of Book/Tax Disparities. If any Partnership property has a Carrying Value on the books of the Partnership different from its adjusted tax basis to the Partnership for U.S. Federal income tax purposes (whether by reason of the contribution of such property to the Partnership or otherwise), allocations of taxable income, gain, loss and deduction under this Article 3 with respect to such asset shall take account of any variation between the adjusted tax basis of such asset for federal income tax purposes and its Carrying Value in the same manner as under Code section 704(c) or the principles set forth in Treasury Regulations section 1.704-1(b)(2)(iv)(g), as the case may be, using the remedial method set forth in Treasury Regulation section 1.7041,704-3(d), unless each of the Partners otherwise agrees.
Appears in 1 contract
Samples: Limited Partnership Agreement (Delta Energy Center, LLC)