Nonallocation of Distributions to Increases in Minimum Gain. To the ----------------------------------------------------------- extent permitted under Treasury Regulation Section 1.704-2(h), distributions to Partners shall not be allocable to increases in the Partnership's Minimum Gain. In general, and except as provided in such regulation, the preceding sentence is intended to insure that reductions in a Partner's Capital Account balance resulting from distributions of money or other property to that Partner are not reversed by the minimum gain chargeback provisions of Section 4.2(b)(iii).
Appears in 2 contracts
Samples: Partnership Agreement (Switzerland County Development Corp), Agreement of Limited Partnership (Hollywood Park Inc/New/)
Nonallocation of Distributions to Increases in Minimum Gain. To the ----------------------------------------------------------- extent extend permitted under Treasury Regulation Section 1.704-2(h), distributions to Partners shall not be allocable to increases in the Partnership's Minimum Gain. In general, and except as provided in such regulation, the preceding sentence is intended to insure that reductions in a Partner's Capital Account balance resulting from distributions of money or other property to that Partner are not reversed revered by the minimum gain chargeback provisions of Section 4.2(b)(iii).
Appears in 1 contract
Samples: Partnership Agreement (Hollywood Park Fall Operating Co)
Nonallocation of Distributions to Increases in Minimum Gain. To the ----------------------------------------------------------- extent permitted under Treasury Regulation Section 1.704I.704-2(h), distributions to Partners shall not be allocable to increases in the Partnership's ’s Minimum Gain. In general, and except as provided in such regulation, the preceding sentence is intended to insure that reductions in a Partner's ’s Capital Account balance resulting from distributions of money or other property to that Partner are not reversed by the minimum gain chargeback provisions of Section 4.2(b)(iii).
Appears in 1 contract