Common use of Partnership Minimum Gain Chargeback Clause in Contracts

Partnership Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding any other provision of Article VI hereof if there is a net decrease in Partnership Minimum Gain during any fiscal year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year (and, if necessary, subsequent fiscal years) in an amount equal to such Partner's share of the net decrease in Partnership Minimum Gain, determined in accordance with 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 Section 1.704-2(f)(6) and 1.704-2(j)(2) of the Regulations. This Section 1(c) is intended to comply with the minimum gain chargeback requirement in Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Partnership Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding Notwithstanding any other provision of Article VI hereof this Section 6, if there is a net decrease in Partnership Partner Minimum Gain during any fiscal yearFiscal Year, then, subject to the exceptions set forth in sections 1.704-2(f)(2), (3), (4) and (5) of the Regulations, each Partner shall be specially allocated items of the Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, subsequent fiscal yearsFiscal Years) in an amount equal to such Partner's ’s share of the net decrease in Partnership Partner Minimum Gain, as determined in accordance with Regulations Section under 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 Section section 1.704-2(f)(6) and 1.704-2(j)(22(f) of the Regulations. This Section 1(c6.2(b) is intended to comply with the minimum gain chargeback requirement requirements in Section section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Partnership Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding Notwithstanding any other provision of Article VI hereof this Agreement to the contrary, if there is a net decrease in Partnership Minimum Gain during any fiscal yearPartnership taxable period, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year period (and, if necessary, subsequent fiscal yearsperiods) in an amount equal to such Partner's share the manner and amounts provided in Sections 1.704-2(f), 1.704-2(g)(2) and 1.704-2(i)(2)(i) of the net decrease in Partnership Minimum GainRegulations, determined in accordance with Regulations Section 1.704-2(g)or any successor provisions. 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 Section Sections 1.704-2(f)(6) and 1.704-2(j)(2) of the Regulations. This Section 1(c2.2(a) is intended to comply with the minimum gain Partnership Minimum Gain chargeback requirement in Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Partnership Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding any other provision of Article VI hereof if If there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, then, except as provided in Regulation Section 1.704-2(f)(2), (3), or (5), each Partner Member shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, for subsequent fiscal yearsFiscal Years) in an amount equal proportion to, and to the extent of, such PartnerMember's share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g)Gain during such Fiscal Year. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner Member pursuant thereto. The thereto and the items to be so allocated shall be determined in accordance with Section Regulation Sections 1.704-2(f)(6) and 1.704-2(j)(2) of ). To the Regulations. This extent that this Section 1(c7.2(c) is intended to comply inconsistent with the minimum gain chargeback requirement in Regulation Section 1.704-2(f) of or incomplete with respect to such Regulations, the Regulations and Partnership Minimum Gain chargeback provided for herein shall be applied and interpreted consistently therewithin accordance with such Regulation.

Partnership Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding any other provision of Article VI hereof if If there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, then, except as provided in Regulation Section 1.704-2(f)(2), (3), or (5), each Partner Member shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, for subsequent fiscal yearsFiscal Years) in an amount equal proportion to, and to the extent of, such Partner's Member’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g)Gain during such Fiscal Year. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner Member pursuant thereto. The thereto and the items to be so allocated shall be determined in accordance with Section Regulation Sections 1.704-2(f)(6) and 1.704-2(j)(2) of ). To the Regulations. This extent that this Section 1(c7.2(c) is intended to comply inconsistent with the minimum gain chargeback requirement in Regulation Section 1.704-2(f) of or incomplete with respect to such Regulations, the Regulations and Partnership Minimum Gain chargeback provided for herein shall be applied and interpreted consistently therewithin accordance with such Regulation.

Partnership Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding any other provision of Article VI hereof if If there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, then, except as provided in Regulation §1.704-2(f)(2), (3), or (5), each Partner Member shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, for subsequent fiscal yearsFiscal Years) in an amount equal proportion to, and to the extent of, such Partner's Member’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g)Gain during such Fiscal Year. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner Member pursuant thereto. The thereto and the items to be so allocated shall be determined in accordance with Section Regulation §1.704-2(f)(6) and §1.704-2(j)(2) of ). To the Regulations. This extent that this Section 1(c7.2(c) is intended to comply inconsistent with the minimum gain chargeback requirement in Section Regulation §1.704-2(f) of or incomplete with respect to such Regulations, the Regulations and Partnership Minimum Gain chargeback provided for herein shall be applied and interpreted consistently therewithin accordance with such Regulation.

Partnership Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding any other provision of Article VI hereof this Exhibit D, if there is a net decrease in Partnership Minimum Gain during any Partnership fiscal year, each Partner shall be specially allocated items of Partnership income and gain 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 Partnership Minimum Gain, determined in accordance with 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 Section sections 1.704-2(f)(62(f) (6) and 1.704-2(j)(22(j) (2) of the Regulations. This Section 1(c3(a) is intended to comply with the minimum gain chargeback requirement in such Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Partnership Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding any other provision of Article VI hereof this Exhibit D, if there is a net decrease in Partnership Minimum Gain during any Partnership fiscal year, each Partner shall be specially allocated items of Partnership income and gain 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 Partnership Minimum Gain, determined in accordance with 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 Section Sections 1.704-2(f)(6) and 1.704l.704-2(j)(2) of the Regulations. This Section 1(c3(a) is intended to comply with the minimum gain chargeback requirement in such Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Partnership Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding any other provision of Article VI hereof this Exhibit B, if there is a net decrease in Partnership Minimum Gain during any Partnership fiscal year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year (and, if necessary, subsequent fiscal years) in an amount equal to such Partner's share of the net decrease in Partnership Minimum Gain, determined in accordance with 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 Section Sections 1.704-2(f)(6) and 1.704-2(j)(2) of the Regulations. This Section 1(c3(a) is intended to comply with the minimum gain chargeback requirement in such Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Partnership Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding any other provision of Article VI hereof if If there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, then, except as provided in Regulations Section 1.704-2(f)(2), (3), or (5), each Partner shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, for subsequent fiscal yearsFiscal Years) in an amount equal proportion to, and to the extent of, such Partner's ’s share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g)Gain during such Fiscal Year. 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 thereto and the items to be so allocated shall be determined in accordance with Section Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2) of the Regulations). This Section 1(c4.4(b) is intended to comply with the minimum gain chargeback requirement in of Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Partnership Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding Notwithstanding any other provision of this Article VI hereof 6, if there is a net decrease in Partnership Minimum Gain during any fiscal yeartax year or other period for which allocations are made, each Partner shall will be specially allocated items of Partnership income and gain for such fiscal year that period (and, if necessary, subsequent fiscal yearsperiods) in an amount equal to such Partner's share of the net decrease in Partnership Minimum Gain, Gain during such tax year or other period determined in accordance with Regulations Section 1.704-2(g2(g)(2). Allocations pursuant to the previous preceding 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 Section Regulations Sections 1.704-2(f)(6) and 1.704-2(j)(2) of the Regulations2(j)(2)(i). This Section 1(c6.2.D(1) is intended to comply with the minimum gain chargeback requirement requirements set forth in Regulations Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith, including the exceptions to the minimum gain chargeback requirement set forth in Regulations Sections 1.704-2(f)(2) and (3).

Partnership Minimum Gain Chargeback. Except as otherwise provided in Treasury Regulation Section 1.704-2(f) of the Regulations), notwithstanding any other provision of this Article VI hereof 5, if there is a net decrease in Partnership Minimum Gain during any fiscal year, each Partner shall be specially allocated items of Partnership income and gain 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 Partnership Minimum Gain, determined in accordance with Regulations Treasury 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 Section Treasury Regulation Sections 1.704-2(f)(6) and 1.704-2(j)(2) of the Regulations). This Section 1(c5.05(a) is intended to comply with the partnership minimum gain chargeback requirement in Treasury Regulation Section 1.704-2(f) of the Regulations and shall be interpreted and applied consistently therewith.

Partnership Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding any other provision of Article VI hereof if If there is a net decrease in Partnership Minimum Gain during any fiscal yearFiscal Year, then, except as provided in Regulation Section 1.704-2(f)(2), (3), or (5), each Partner Member shall be specially allocated items of Partnership income and gain for such fiscal year Fiscal Year (and, if necessary, for subsequent fiscal yearsFiscal Years) in an amount equal proportion to, and to the extent of, such PartnerMember's share of the net decrease in Partnership Minimum Gain, determined in accordance with Regulations Section 1.704-2(g)Gain during such Fiscal Year. Allocations pursuant to the previous sentence shall be made in proportion to the respective amounts required to be allocated to each Partner Member pursuant thereto. The thereto and the items to be so allocated shall be determined in accordance with Section Regulation Sections 1.704-2(f)(6) and 1.704-2(j)(2) of ). To the Regulations. This extent that this Section 1(c3.2(c) is intended to comply inconsistent with the minimum gain chargeback requirement in Regulation Section 1.704-2(f) of or incomplete with respect to such Regulations, the Regulations and Partnership Minimum Gain chargeback provided for herein shall be applied and interpreted consistently therewithin accordance with such Regulation.

Partnership Minimum Gain Chargeback. Except as otherwise -------------------------------------- provided in Section 1.704-2(f) of the Regulations, notwithstanding any other provision of Article VI hereof if there is a net decrease in Partnership Minimum Gain during any fiscal year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year (and, if necessary, subsequent fiscal years) in an amount equal to such Partner's share of the net decrease in Partnership Minimum Gain, determined in accordance with 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 Section 1.704l.704-2(f)(6) and 1.704-2(j)(2) of the Regulations. This Section 1(c) is intended to comply with the minimum gain chargeback requirement in Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Partnership Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding any other provision of Article VI hereof this Article, if there is a net decrease in Partnership Minimum Gain during any fiscal yearAllocation Period, each Partner Member shall be specially allocated items of Partnership Company income and gain for such fiscal year Allocation Period (and, if necessary, subsequent fiscal yearsAllocation Periods) in an amount equal to such Partner's Member’s share of the net decrease in Partnership Minimum Gain, determined in accordance with 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 Member pursuant thereto. The items to be so allocated shall be determined in accordance with Section Sections 1.704-2(f)(6) and 1.704-2(j)(2) of the Regulations. This Section 1(c4.2(a) is intended to comply with the minimum gain chargeback requirement in Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Partnership Minimum Gain Chargeback. Except as otherwise -------------------------------------- provided in Section 1.704-2(f) of the Regulations, notwithstanding any other provision of Article VI hereof if there is a net decrease in Partnership Minimum Gain during any fiscal year, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year (and, if necessary, subsequent fiscal years) in an amount equal to such Partner's share of the net decrease in Partnership Minimum Gain, determined in accordance with 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 Section 1.704-2(f)(6) and 1.7041 .704-2(j)(2) of the Regulations. This Section 1(c) is intended to comply with the minimum gain chargeback requirement in Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.

Partnership Minimum Gain Chargeback. Except as otherwise provided in Section 1.704-2(f) of the Regulations, notwithstanding Notwithstanding any other provision of Article VI hereof this Agreement to the contrary, if there is a net decrease in Partnership Minimum Gain during any fiscal yearPartnership taxable period, each Partner shall be specially allocated items of Partnership income and gain for such fiscal year period (and, if necessary, subsequent fiscal yearsperiods) in an amount equal to such Partner's share the manner and amounts provided in Sections 1.704-2(f), 1.704-2(g)(2) and 1.704-2(j)(2)(i) of the net decrease in Partnership Minimum GainRegulations, determined in accordance with Regulations Section 1.704-2(g)or any successor provisions. 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 Section Sections 1.704-2(f)(62(0(6) and 1.704-2(j)(2) of the Regulations. This Section 1(c2.2(a) is intended to comply with the minimum gain Partnership Minimum Gain chargeback requirement in Section 1.704-2(f) of the Regulations and shall be interpreted consistently therewith.