Partnership for Tax Purposes. The Partnership is, and at all times has been, properly treated as a partnership for Federal Income Tax purposes, and not as an "association" or "publicly traded partnership" taxable as a corporation. The foregoing representation shall survive Closing without being subject to the one year limitation.
Appears in 4 contracts
Samples: Contribution Agreement (First Washington Realty Trust Inc), Contribution Agreement (First Washington Realty Trust Inc), Contribution Agreement (First Washington Realty Trust Inc)
Partnership for Tax Purposes. The Partnership Company is, and at all times has been, properly treated as a partnership "division" of Contributor for Federal Income Tax purposes, and the Company itself has not been treated as an "association" or "publicly traded partnership" taxable as a corporation. The foregoing representation shall survive Closing without being subject to the one year limitation.
Appears in 1 contract
Samples: Contribution Agreement (First Washington Realty Trust Inc)
Partnership for Tax Purposes. The Partnership is, and at all times has been, properly treated as a partnership for Federal Income Tax purposes, and not as an "association" or "publicly traded partnership" taxable as a corporation. The foregoing representation shall survive Closing without being subject to the one year limitation.
Appears in 1 contract
Samples: Contribution Agreement (First Washington Realty Trust Inc)
Partnership for Tax Purposes. The Partnership is, and at all times has been, properly treated as a partnership for Federal Income Tax purposes, and not as an "association" or "publicly traded partnership" taxable as a corporation. The foregoing representation set forth in this Section 7(r) shall survive Closing without being subject to the one year six (6) month limitation.
Appears in 1 contract
Samples: Agreement to Sell Partnership Interests (Corporate Office Properties Trust)
