Common use of Intent of Allocations Clause in Contracts

Intent of Allocations. The parties intend that the allocation provisions of this Exhibit A shall result in final Capital Account balances of the Partners that equal to the amounts distributable to the Partners in accordance with paragraph 4(b) of this Exhibit A, so that when liquidating distributions are made in accordance with such final Capital Account balances under Section 14.2A(4) hereof, such distributions will be able to return to each Partner the amounts distributable to the Partner in accordance with paragraph 4(b) of this Exhibit A. To the extent that such final Capital Account balances do not so reflect the intent of this Exhibit A, income and loss of the Partnership for the current year and future years, as computed for book purposes, shall be allocated among the Partners so as to result in final Capital Account balances reflecting the intent of this Exhibit A. This subparagraph shall control notwithstanding any reallocation of income, loss, or items thereof, as computed for book purposes, by the Internal Revenue Service or any other taxing authority.