Limited Partnership. The Company has been formed as a limited partnership under and pursuant to the Delaware Act. The Board of Directors and the Partners specifically intend and agree that the Company shall, for purposes of the Code and state tax laws, be classified as a partnership and none of them shall make any election or take any other action that would cause their relationship under this Agreement to be excluded from the application of all or any part of Subchapter K of the Code (or any successor provisions). The Partners specifically intend and agree that the Company shall be a limited partnership pursuant to the Delaware Act and not any other type of venture.
Appears in 6 contracts
Samples: Partnership Agreement (Special Value Continuation Partners, LP), Partnership Agreement (Special Value Continuation Partners, LP), Partnership Agreement (Special Value Continuation Fund, LLC)