Common use of Elimination of Book/Tax Disparities Clause in Contracts

Elimination of Book/Tax Disparities. In determining a Partner's allocable share of Partnership taxable income, the Partner's allocable share of each item of Profits and Losses shall be properly adjusted to reflect the difference between such Partner's share of the adjusted tax basis and the Book Value of Partnership assets used in determining such item under any method adopted by the Tax Matters Partner and allowable under Code Section 704(c), provided, however, that any deductions for depreciation or amortization attributable to property contributed to the Partnership by a Partner shall be allocated to the Partner contributing such property. In the event that the method for the allocation of depreciation or amortization deductions attributable to contributed property described in the previous sentence is disallowed, then the Tax Matters Partner shall make such compensating allocations of items including (notwithstanding the second sentence of Section 4.3(a)) such book allocations as are intended to accomplish the same economic result.

Appears in 2 contracts

Samples: Partnership Agreement (Garden State Newspapers Inc), Partnership Agreement (Medianews Group Inc)

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Elimination of Book/Tax Disparities. In determining a Partner's allocable share of Partnership taxable income, the Partner's allocable share of each item of Profits and Losses shall be properly adjusted to reflect the difference between such Partner's share of the adjusted tax basis and the Book Value of Partnership assets used in determining such item under any method adopted by the Tax Matters Partner and allowable under Code Section 704(c), provided, however, that any deductions for depreciation or amortization attributable to property contributed to the Partnership by a Partner shall be allocated to the Partner contributing such property. In the event that the method for the allocation of depreciation or amortization deductions attributable to contributed property described in the previous sentence is disallowed, then the Tax Matters Partner shall make such compensating allocations of items including (notwithstanding the second sentence of Section 4.3(a)) such book allocations as are intended to accomplish the same economic result.Section

Appears in 1 contract

Samples: Partnership Agreement (Medianews Group Inc)

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Elimination of Book/Tax Disparities. In determining a Partner's ’s allocable share of Partnership taxable income, the Partner's ’s allocable share of each item of Profits and Losses shall be properly adjusted to reflect the difference between such Partner's ’s share of the adjusted tax basis and the Book Value of Partnership assets used in determining such item under any method adopted by the Tax Matters Partner and allowable under Code Section 704(c), provided, however, that any deductions for depreciation or amortization attributable to property contributed to the Partnership by a Partner shall be allocated to the Partner contributing such property. In the event that the method for the allocation of depreciation or amortization deductions attributable to contributed property described in the previous sentence is disallowed, then the Tax Matters Partner shall make such compensating allocations of items including (notwithstanding the second sentence of Section 4.3(a)) such book allocations as are intended to accomplish the same economic result.

Appears in 1 contract

Samples: Partnership Agreement (Medianews Group Inc)

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