Common use of Minimum Gain Chargeback Clause in Contracts

Minimum Gain Chargeback. Except as otherwise provided in Regulation §1.704-2(f), notwithstanding any other provision of this Section, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) during any Year, each Partner shall be specially allocated items of income and gain of the Partnership for such Year (and, if necessary, subsequent Years) in an amount equal to such Partner’s share of the net decrease in minimum gain, determined in accordance with Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Regulations Section 1.704-2(f), notwithstanding the provisions of Section 6.2, or any other provision of this SectionArticle 6, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Yearfiscal year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Year year (and, if necessary, subsequent Yearsyears) in an amount equal to such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, as determined in accordance with Regulation §under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Regulations Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.Section

Minimum Gain Chargeback. Except as otherwise provided in Regulation §§ 1.704-2(f), notwithstanding any other provision of this Section, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) during any Year, each Partner shall be specially allocated items of income and gain of the Partnership for such Year (and, if necessary, subsequent Years) in an amount equal to such Partner’s share of the net decrease in minimum gain, determined in accordance with Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Regulations Section 1.704-2(f), notwithstanding any other provision of this SectionArticle 5, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in minimum gainMinimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Regulations Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(22(g)(2). This Section 4.01(c)(i5.03(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Regulations Section 1.704-2(f), notwithstanding any other provision of this SectionArticle 5, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any YearPartnership taxable year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Year taxable year (and, if necessary, subsequent Yearstaxable years) in an amount equal to such Partner’s share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Regulations Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i5.3(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Regulations Section 1.704-2(f), notwithstanding any other provision of this SectionArticle V, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in minimum gainMinimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Regulations Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(22(g)(2). This Section 4.01(c)(i5.3 (a) is intended to comply with the minimum gain chargeback requirement in Regulation §Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionSection 3, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2)) of the Regulations. This Section 4.01(c)(i3.3 (a) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionArticle 3, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Section 1.704-2(g)) of the Regulations. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Section 1.704-2(f)(6) and Regulation §Section 1.704-2(j)(2)) of the Regulations. This Section 4.01(c)(i3.2(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Regulations Section 1.704-2(f), notwithstanding the provisions of Section 4.2 of this Agreement, or any other provision of this SectionArticle 4, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Year year (and, if necessary, subsequent Yearsyears) in an amount equal to such Partner’s share of the net decrease in minimum gainPartnership Minimum Gain, as determined in accordance with Regulation §under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Regulations Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(22(j). This Section 4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Regulations Section 1.704-2(f), notwithstanding any other provision of this SectionSection 3, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Regulations Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i3.3(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §section 1.704-2(f), notwithstanding any other provision ) of this Sectionthe Regulations, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such Partner’s share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §section 1.704-2(g)) of the Regulations. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2)2(g)(2) of the Regulations. This Section 4.01(c)(i6.3(c) is intended to comply with the minimum gain chargeback requirement in Regulation §section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionSection 5.3, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such Partner’s 's share of the net decrease in minimum gain, Partnership Minimum Gain determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2)) of the Regulations. This Section 4.01(c)(i5.3(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §1.704-2(f), notwithstanding any other provision of this Section, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) during any Year, each Partner shall be specially allocated items of income and gain of the Partnership for such Year (and, if necessary, subsequent Years) in an amount equal to such Partner’s share of the net decrease in minimum gain, determined in accordance with Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i4.01 (c)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Regulations Section 1.704-2(f), notwithstanding the provisions of Section 6.2 of the Agreement, or any other provision of this SectionArticle 6, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Yearfiscal year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Year year (and, if necessary, subsequent Yearsyears) in an amount equal to such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, as determined in accordance with Regulation §under Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Regulations Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.Section

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Regulations Section 1.704-2(f), notwithstanding any other provision of this SectionSection 12, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Fiscal Year, each Partner shall be specially specifically allocated items of Partnership income and gain of the Partnership for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such the Partner’s share of the net decrease in minimum gain, Partnership Minimum Gain as determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to made in accordance with the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated under this Section 12.2(a) shall be determined in accordance with Regulation §Regulations Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i12.2(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Regulations 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionSection 6.1, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any YearAdjustment Period, each Partner shall be specially allocated items of gross income and gain of the Partnership for such Year period (and, if necessary, subsequent Yearsperiods) in an amount equal to such Partner’s share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Section 1.704-2(g)) of the Regulations. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Section 1.704-2(f)(6) and Regulation §1.704-2(j)(2)) of the Regulations. This Section 4.01(c)(i6.1(c)(ii) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §1.704-Section 1.704- 2(f), notwithstanding any other provision provisions of this SectionArticle 4, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) during Partnership Minimum Gain for any Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Year year (and, if necessary, subsequent Yearsyears) in an amount equal to the such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, as determined in accordance with under Regulation §Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i) Section 4.3.1 is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) such sections of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionSection 5.02, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2)) of the Regulations. This Section 4.01(c)(i5.02(b)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionArticle V, if there is a net decrease in Partnership minimum gain (as defined in Regulation §1.704-2(b)(2)) during any YearPartnership fiscal year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Year fiscal year (and, if necessary, subsequent Yearsfiscal years) in an amount equal to such Partner’s share of the net decrease in Partnership minimum gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2)1(j)(2) of the Regulations. This Section 4.01(c)(i5.3(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f1(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)2 (f) of the Regulations, notwithstanding any other provision of this SectionSection 5.0l, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Partnership Fiscal Year, each Partner shall be specially specifically allocated items of Partnership income and gain of the Partnership for such Partnership Fiscal Year (and, if necessary, subsequent Partnership Fiscal Years) in an amount equal to such Partner’s Partners' share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §1.704Regulations Section l.704-2(g2 (g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(62 (f) (6) and Regulation §1.704-2(j)(2)2 (j) (2) of the Regulations. This Section 4.01(c)(i5.01 (b) (i) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f2 (f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §1.704-2(f), notwithstanding any other provision of this Section, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) during any Year, each Partner shall be specially allocated items of income and gain of the Partnership for such Year (and, if necessary, subsequent Years) in an amount equal to such Partner’s share of the net decrease in minimum gain, determined in accordance with Regulation §§ 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Regulations Section 1.704-2(f)2(0, notwithstanding any other provision of this SectionArticle III, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Regulations Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i3.3(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §1.704-2(f), notwithstanding any other provision of this Section, if there is a net decrease in minimum gain (as defined in Regulation §§ 1.704-2(b)(2)) during any Year, each Partner shall be specially allocated items of income and gain of the Partnership for such Year (and, if necessary, subsequent Years) in an amount equal to such Partner’s share of the net decrease in minimum gain, determined in accordance with Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §§ 1.704-2(f), notwithstanding any other provision of this Section, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) during any Year, each Partner shall be specially allocated items of income and gain of the Partnership for such Year (and, if necessary, subsequent Years) in an amount equal to such Partner’s share of the net decrease in minimum gain, determined in accordance with Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §1.704-2(f)(6) and Regulation §§ 1.704-2(j)(2). This Section 4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §1.704-2(f), notwithstanding any other provision of this Section, if there is a net decrease in minimum gain (as defined in Regulation §§ 1.704-2(b)(2)) during any Year, each Partner shall be specially allocated items of income and gain of the Partnership Table of Contents for such Year (and, if necessary, subsequent Years) in an amount equal to such Partner’s share of the net decrease in minimum gain, determined in accordance with Regulation §§ 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionSection 3, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any YearPartnership fiscal year, each General Partner and Interest Holder shall be specially allocated items of Partnership income and gain of the Partnership for such Year year (and, if necessary, subsequent Yearsyears) in an amount equal to such PartnerPerson’s share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each General Partner and Interest Holder pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(62(f) (6) and Regulation §1.704-2(j)(2)2 (j) (2) of the Regulations. This Section 4.01(c)(i3. 3 (a) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Regulations Section 1.704-2(f), notwithstanding any other provision of this SectionSection 12, if there is a BHC OF INDIANA, GENERAL PARTNERSHIP - 7 - net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Fiscal Year, each Partner shall be specially specifically allocated items of Partnership income and gain of the Partnership for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such the Partner’s share of the net decrease in minimum gain, Partnership Minimum Gain as determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to made in accordance with the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated under this Section 12.2(a) shall be determined in accordance with Regulation §Regulations Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i12.2(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Regulations 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Regulations Section 1.704-2(f), notwithstanding any other provision of this SectionSection 12, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Fiscal Year, each Partner shall be specially specifically allocated items of Partnership income and gain of the Partnership for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such the Partner’s 's share of the net decrease in minimum gain, Partnership Minimum Gain as determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to made in accordance with the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated under this Section 12.2(a) shall be determined in accordance with Regulation §Regulations Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i12.2(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Regulations 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionArticle IV, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2)) of the Regulations. This Section 4.01(c)(i4.3(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)2 (f) of the Regulations, notwithstanding any other provision of this SectionSection 3, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g2 (g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(62 (f) (6) and Regulation §1.704-2(j)(2)2(j) (2) of the Regulations. This Section 4.01(c)(i3.3 (a) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f2 (f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionSection 3, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2)) of the Regulations. This Section 4.01(c)(i3.3(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §1.704-2(f), notwithstanding Notwithstanding any other provision of this SectionArticle 8, if there is a net decrease in minimum gain (as defined Partnership Minimum Gain during any Fiscal Year or other applicable period, then, subject to the exceptions set forth in Regulation §Regulations Section 1.704-2(b)(22(f)(2), (3), (4) during any Yearand (5), each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, as determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Regulations Section 1.704-2(f)(6) and Regulation §1.704-2(j)(22(f). This Section 4.01(c)(i8.2(a)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §Regulations Section 1.704-2(f) and the safe-harbor for such chargebacks and offsets contained in Regulations Section 1.514(c)-2(e)(1)(ii) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §1.704-2(f), notwithstanding Notwithstanding any other provision of this SectionAppendix A, if there is a net decrease in minimum gain (as defined Partnership Minimum Gain during any Fiscal Year, then, subject to the exceptions set forth in Regulation §Regulations § 1.704-2(b)(22(f)(2), (3), (4) during any Yearand (5), each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Year year (and, if necessary, subsequent Yearsyears) in an amount equal to such Partner’s share of the net decrease in minimum gainPartnership Minimum Gain, as determined in accordance with Regulation §under Regulations § 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in such section of the Regulations in accordance with Regulation §Regulations § 1.704-2(f)(6) and Regulation §1.704-2(j)(22(f). This Section 4.01(c)(i2.2(A) is intended to comply with the minimum gain chargeback requirement requirements in Regulation §Regulations § 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section ----------------------- 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionAgreement, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2)) of the Regulations. This Section 4.01(c)(i15.4(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §1.704-2(f), notwithstanding any other provision of this Section, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) during any Year, each Partner shall be specially allocated items of income and gain of the Partnership for such Year (and, if necessary, subsequent Years) in an amount equal to such Partner’s share of the net decrease in minimum gain, determined in accordance with Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §§ 1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionArticle 0, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Yearfiscal year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Year fiscal year (and, if necessary, subsequent Yearsfiscal years) in an amount equal to such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2)) of the Regulations. This Section 4.01(c)(i) 0 is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionArticle VI, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Yearyear, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Year year (and, if necessary, subsequent Yearsyears) in an amount equal to such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2)) of the Regulations. This Section 4.01(c)(i6.6(a) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(fSection 1.7042(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Regulations Section 1.704-2(f), notwithstanding any other provision of this SectionArticle VI, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Regulations Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i6.03(A) is intended to comply with the minimum gain chargeback requirement in Regulation §Regulations Section 1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §1.704-2(f), notwithstanding any other provision of this Section, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) during any Year, each Partner shall be specially allocated items of income and gain of the Partnership for such Year (and, if necessary, subsequent Years) in an amount equal to such Partner’s share of the net decrease in minimum gain, determined in accordance with Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §1.7041,704-2(f)(6) and Regulation §1.704-2(j)(2). This Section 4.01(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionSection 3, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Allocation Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Allocation Year (and, if necessary, subsequent Allocation Years) in an amount equal to such Partner’s Partner ‘s share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2)) of the Regulations. This Section 4.01(c)(i3.3(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionSection 6, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Partnership Fiscal Year, each General Partner and Limited Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such Partner’s Person's share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each General Partner and Limited Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §Sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2)) of the Regulations. This Section 4.01(c)(i6.03 (a) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §1.704-2(f)Section 1.704–2(f) of the Regulations, notwithstanding any other provision of this SectionExhibit C or of Article V, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such Partner’s share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §1.704-2(gRegulations Section 1.704–2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §1.704-2(f)(6Sections 1.704–2(f)(6) and Regulation §1.704-2(j)(2)1.704–2(j)(2) of the Regulations. This Section 4.01(c)(iC.3(a) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(fSection 1.704–2(f) of the Regulations and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §1.704-2(f), notwithstanding any other provision of this Section, if there is a net decrease in minimum gain (as defined in Regulation §1.7041,704-2(b)(2)) during any Year, each Partner shall be specially allocated items of income and gain of the Partnership for such Year (and, if necessary, subsequent Years) in an amount equal to such Partner’s share of the net decrease in minimum gain, determined in accordance with Regulation §1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §1.704-2(f)(6) and Regulation §1.704-2(j)(22(i)(2). This Section 4.01(c)(i4.0.1(c)(i) is intended to comply with the minimum gain chargeback requirement in Regulation §1.704-2(f) and shall be interpreted consistently therewith.

Minimum Gain Chargeback. Except as otherwise provided in Regulation §Section 1.704-2(f)) of the Regulations, notwithstanding any other provision of this SectionSection 5, if there is a net decrease in minimum gain (as defined in Regulation §1.704-2(b)(2)) Partnership Minimum Gain during any Fiscal Year, each Partner shall be specially allocated items of Partnership income and gain of the Partnership for such Fiscal Year (and, if necessary, subsequent Fiscal Years) in an amount equal to such Partner’s 's share of the net decrease in minimum gainPartnership Minimum Gain, determined in accordance with Regulation §Regulations Section 1.704-2(g). Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner pursuant thereto. The items to be so allocated shall be determined in accordance with Regulation §sections 1.704-2(f)(6) and Regulation §1.704-2(j)(2)) of the Regulations. This Section 4.01(c)(i5.3(a) is intended to comply with the minimum gain chargeback requirement in Regulation §Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.