Common use of Partnership Status for Income Tax Purposes Clause in Contracts

Partnership Status for Income Tax Purposes. The Partners intend that the Partnership shall be treated as a partnership for federal, state, and local income tax purposes, and the Partnership shall not elect, and the General Partner shall not permit the Partnership to elect, to be treated as an association taxable as a corporation for federal, state, or local income tax purposes under Regulations Section 301.7701-3 or under any corresponding provision of state or local law. Each Partner and the Partnership shall file all tax returns consistent with such treatment. Notwithstanding the foregoing restriction in Section 7.03(c), the General Partner may cause the Partnership to be converted into a corporation pursuant to Section 7.04.