Common use of PARTNER SECTION 482 ADJUSTMENT Clause in Contracts

PARTNER SECTION 482 ADJUSTMENT. If the Internal Revenue Service reallocates an item of income, deduction, or loss to a Partner or an Affiliate pursuant to Section 482 of the Code or any similar rule or principle of law (a "Partner Section 482 Allocation"), and the Partnership has a corresponding correlative item of deduction, loss or income (as determined under Section 1.482-1(g) of the Regulations (the "Partnership Correlative Item"), such Partnership Correlative Item shall be specially allocated to and reflected in the Capital Account of the Partner that received (or whose Affiliate received) such Partner Section 482 Allocation, and a corresponding contribution or distribution shall likewise be deemed to have been made by or to such Partner.

PARTNER SECTION 482 ADJUSTMENT. If the Internal Revenue Service reallocates an item of income, deduction, deduction or loss to a Partner or an Affiliate of such Partner pursuant to Section 482 of the Code or any similar rule or principle of law (a "Partner Section 482 Allocation"), and the Partnership has a corresponding correlative item of deduction, loss or income (as determined under Section 1.482-1(g)) of the Regulations (the "Partnership Correlative Item"), such Partnership Correlative Item shall be specially allocated to and reflected in the Capital Account of the Partner that received (or whose Affiliate received) such Partner Section 482 Allocation, and a corresponding deemed contribution or distribution shall likewise be deemed to have been made by or allocated to such Partner.