Common use of Partnership Classification Clause in Contracts

Partnership Classification. It is the intention of the parties hereto that the Company be treated as a partnership for federal, state and local income tax purposes. The Company shall not elect to be treated as other than a partnership under Treasury Regulations Section 301.7701-3(c) (or any corresponding applicable provisions of state or local law) unless such election is approved by all of the Managers.

Appears in 4 contracts

Samples: Operating Agreement, Limited Liability Company Agreement (Nevada Property 1 LLC), Operating Agreement (Nevada Property 1 LLC)

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Partnership Classification. It is the intention of the parties hereto that the Company be treated as a partnership for federal, state and local income tax purposes. The Company shall not elect to be treated as other than a partnership corporation under Treasury Regulations Section § 301.7701-3(c) of the Code (or any corresponding applicable provisions of state or local law) unless such election is approved by all of the ManagersBoard.

Appears in 3 contracts

Samples: Limited Liability Company Agreement (American Casino & Entertainment Properties LLC), Limited Liability Company Agreement (Colony Resorts LVH Acquisitions LLC), Limited Liability Company Agreement (Colony Resorts LVH Acquisitions LLC)

Partnership Classification. It is the intention of the parties hereto The Members intend that the Company be treated as a partnership for federal, state and local income tax purposes. The , and the Company shall will not elect to be treated as other than a partnership corporation under Treasury Regulations Regulation Section 301.7701-3(c) (or any corresponding applicable provisions provision of state or local law) unless such election is approved by all of the Managers).

Appears in 2 contracts

Samples: Operating Agreement (Palmsource Inc), Operating Agreement (Palm Inc)

Partnership Classification. It is the intention of the parties hereto that the Company be treated as a partnership for federal, state and local income tax purposes. The Company shall not elect to be treated as other than a partnership corporation under Treasury Regulations Section 301.7701-3(c) (or any corresponding applicable provisions of state or local law) unless ). The Members hereby agree that the provisions of this Agreement shall be applied and construed in a manner to give full effect to such election is approved by all of the Managersintent.

Appears in 1 contract

Samples: Limited Liability Company Agreement (TD Group Holdings, LLC)

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Partnership Classification. It is the intention of the parties hereto that the Company be treated as a partnership for federal, state and local income tax purposes. The Company shall not elect to be treated as other than a partnership corporation under Treasury Regulations Section 301.7701-3(c) of the Code (or any corresponding applicable provisions of state or local law) unless such election is approved by all of the ManagersBoard.

Appears in 1 contract

Samples: Limited Liability Company Agreement (Colony Resorts LVH Acquisitions LLC)

Partnership Classification. It is the intention of the parties hereto that the Company be treated as a partnership for federal, state and local income tax purposes. The Company shall not elect to be treated as other than a partnership corporation under Treasury Regulations Section § 301.7701-3(c) of the Code (or any corresponding applicable provisions of state or local law) unless such election is approved by all the Board. The Members hereby agree that the provisions of the Managersthis Agreement shall be applied and construed in a manner to give full effect to such intent.

Appears in 1 contract

Samples: Operating Agreement (Ev3 Inc.)

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