General Allocation of Profits and Losses. Except as otherwise provided in this Article 7, after giving effect to any and all allocations set forth in Section 7.4 below, all Profits and Losses of the Partnership (including all items of income and expense entering into the determination of such Profits and Losses), as finally determined for Federal income tax purposes for each fiscal year of the Partnership, shall be allocated to and among the Partners in accordance with their respective Percentage Interests.
General Allocation of Profits and Losses. After giving effect to the allocations set forth in Sections 7.5 and 7.6, all Profits and Losses (including all items of income and expense entering into the determination of such Profits and Losses), as finally determined for federal income tax purposes for each fiscal year of the Company, shall be allocated among the Members as follows:
General Allocation of Profits and Losses. After taking into account any special allocations pursuant to Section 4.2 and subject to any limitations contained therein, Profits or Losses for each year shall be allocated among the Members in accordance with this Section 4.1.
General Allocation of Profits and Losses. After giving effect to the special allocations set forth in Sections 5.3 through 5.6 hereof, the Profits and Losses for any fiscal year, or portion thereof, as applicable, shall be allocated to the Partners in accordance with the Partnership Percentages of the respective Partners.
General Allocation of Profits and Losses. After taking into account any special allocations pursuant to Section 4.02 and subject to any limitations contained therein, Profits, Losses and, to the extent necessary, individual items of income, gain, loss or deduction, of the Company shall be allocated among the Members in a manner such that the Capital Account of each Member, immediately after making such allocation, is, as nearly as possible, equal (proportionately) to the distributions that would be made to such Member if the Company were dissolved, its affairs wound up and its assets sold for cash equal to their Book Value, all Company liabilities were satisfied (limited with respect to each nonrecourse liability to the Book Value of the assets securing such liability), and the net assets of the Company were distributed in accordance with Article III to the Members immediately after making such allocation.
General Allocation of Profits and Losses. 7.2 Allocations with Respect to Transferred Interests........................................................... 7.3
General Allocation of Profits and Losses. Subject to, and after taking into account allocations pursuant to the provisions of Section 5.4, for each Fiscal Year or portion thereof, Profits and Losses of the Company and, to the extent determined necessary and appropriate by the Board to achieve the resulting Capital Account balances described below, any individual items of income, gain, loss, credit and deduction includable in the computation of Profits and Losses, for such Fiscal Year or portion thereof shall be allocated among the Members during such Fiscal Year or portion thereof in such a manner that, as of the end of such period and after these allocations are made, the sum of (i) the Capital Account of the Member and (ii) that Member’s share of “partnership minimum gain” (as defined and determined in accordance with Sections 1.704-2(b)(2) and 1.704-2(d) of the Regulations), if any, and “partner nonrecourse debt minimum gain” (as defined and determined in accordance with Sections 1.704-2(i)(2) and 1.704-2(i)(3) of the Regulations), if any, computed immediately prior to the hypothetical sale of assets referenced below, and the amount any such Member is treated as obligated to contribute to the Company, computed immediately after the hypothetical sale of assets referenced below, shall be equal to the respective net amounts that would be distributed to that Member if the Company sold all of its properties for cash equal to their Gross Asset Values (or, for the amount of Company Nonrecourse Liabilities or Partner Nonrecourse Debt secured by the Company properties, if Company Nonrecourse Liabilities or Partner Nonrecourse Debt exceed Gross Asset Values), satisfied all of the liabilities on the Company’s balance sheet as computed for Capital Account purposes, except to the extent of any Company Minimum Gain and Partner Nonrecourse Debt Minimum Gain, and distributed the remaining proceeds to the Members in accordance with Section 11.3(b)(iii).
General Allocation of Profits and Losses. After taking into account any special allocations pursuant to Section 4.02 and subject to any limitations contained therein, Profits and Losses for any year or portion thereof shall be allocated among the Partners in accordance with this Section 4.01.
(a) Profits. Profits shall be allocated among the Partners as follows:
(i) First, among the Partners who have previously been allocated Losses pursuant to Section 4.01(b)(ii) in the same proportion as such Losses have been allocated, until the cumulative Profits allocated to each Partner pursuant to this Section 4.01(a)(i) equal the cumulative Losses allocated to each Partner pursuant to Section 4.01(b)(ii);
(ii) Then, among all of the Partners in accordance with their Percentage Interests.
(b) Losses. Losses shall be allocated among the Partners as follows:
(i) First, among the Partners who have previously been allocated Profits pursuant to Section 4.01(a)(ii) in the same proportion as such Profits have been allocated, until the cumulative Losses allocated to each Partner pursuant to this Section 4.01(b)(i) equal the cumulative Profits allocated to each Partner pursuant to Section 4.01(a)(ii);
(ii) Then, among all of the Partners in accordance with their Percentage Interests.
(c) The Partners intend that the allocations of Profits and Losses in Section 4.01(a) and Section 4.01(b) result in a Capital Account balance for each Partner on liquidation of the Partnership that is equal to the amount that would be distributed to such Partner if liquidating distributions were made in accordance with Article 3 of this Agreement. In the year of liquidation of the Partnership, if the allocations set forth in Section 4.01(a) and Section 4.01(b) would result in Capital Account balances that are not as described in the preceding sentence, Profits and Losses and, if necessary, items of gross income and deduction shall be specially allocated among the Partners to the extent necessary to cause each Partner’s Capital Account balance to be equal to the amount that would be distributed to such Partner if liquidating distributions were made in accordance with Article 3 of this Agreement.
General Allocation of Profits and Losses. Except as otherwise provided in this Agreement or the Joint Agreement, the profits and losses of the Partnership arising during any taxable year of the Partnership shall be allocated among the Partners in accordance with their respective Partnership Percentages; provided, however, that in accordance with Section 704(c) of the Code and the Treasury Regulations thereunder, income, gain, loss, and deduction with respect to any property contributed to the capital of the Partnership shall, solely for tax purposes, be allocated among the Partners so as to take account of any variation between the adjusted basis of PATRXXXX X. XXXXX & XSSOCIATES A PROFESSIONAL LAW CORPORATION GENERAL PARTNERSHIP AGREEMENT such property to the Partnership for federal income tax purposes and its agreed upon fair market value at the time of contribution.
General Allocation of Profits and Losses. Except as otherwise provided in this Agreement, the profits and losses of the Company shall be allocated to or deducted from, the Capital Accounts of the Members, annually or more frequently, in accordance with their Percentage Interests.
