Partnership Tax Status. The Partners intend that the Partnership shall be treated as a partnership for U.S. Federal, state and local income tax purposes and hereby agree, and authorize the Partnership and the Tax Matters Partner to take such actions (including the making of, or refraining from making, any relevant elections) to perfect such status. The Partners further intend that the provisions of sections 6221-6234 of the Code shall apply to the Partnership and intend that, if the circumstances so require, an election under section 6231(a)(1)(B)(ii) of the Code shall be made. The Board shall have authority to amend or supplement the provisions of this Section 6.4 from time to time, as it sees fit.
Appears in 4 contracts
Samples: Limited Partnership Agreement (Delta Energy Center, LLC), Limited Partnership Agreement (Delta Energy Center, LLC), Agreement of Limited Partnership (Delta Energy Center, LLC)
Partnership Tax Status. The Partners intend that the Partnership shall be treated as a partnership disregarded entity for U.S. Federal, state and local income Federal tax purposes and hereby agree, and authorize the Partnership and the Tax Matters Partner to take such actions (including the making of, or refraining from making, any relevant elections) to perfect such status. The Partners further intend that the provisions of sections 6221-6234 of the Code shall apply to the Partnership and intend that, if the circumstances so require, an election under section 6231(a)(1)(B)(ii) of the Code shall be made. The Board shall have authority to amend or supplement the provisions of this Section 6.4 from time to time, as it sees fit.
Appears in 4 contracts
Samples: Limited Partnership Agreement (Delta Energy Center, LLC), Limited Partnership Agreement (Delta Energy Center, LLC), Limited Partnership Agreement (Delta Energy Center, LLC)
Partnership Tax Status. The Partners intend that the Partnership shall be treated as a partnership for U.S. Federal, state and local income tax purposes and hereby agree, and authorize the Partnership and the Tax Matters Partner to take such actions (including the making of, or refraining from making, any relevant elections) to perfect such status. The Partners further intend that the provisions of sections 6221-6234 6221 -6234 of the Code shall apply to the Partnership and intend that, if the circumstances so require, an election under section 6231(a)(1)(B)(ii) of the Code shall be made. The Board shall have authority to amend or supplement the provisions of this Section 6.4 from time to time, as it sees fit.
Appears in 1 contract
Samples: Limited Partnership Agreement (Delta Energy Center, LLC)
Partnership Tax Status. The Partners Members intend that the Partnership Company shall be treated as a partnership for U.S. Federal, state and local income tax purposes and hereby agree, and authorize the Partnership Company and the Tax Matters Partner to take such actions (including the making of, or refraining from making, any relevant elections) to perfect such status. The Partners Members further intend that the provisions of sections 6221-6234 of the Code shall apply to the Partnership Company and intend that, if the circumstances so require, an election under section 6231(a)(1)(B)(ii) of the Code shall be made. The Board shall have authority to amend or supplement the provisions of this Section 6.4 from time to time, as it sees fit.
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Delta Energy Center, LLC)
Partnership Tax Status. The Partners intend that the Partnership shall be treated as a partnership for U.S. Federal, state and local income tax purposes and hereby agree, and authorize the Partnership and the Tax Matters Partner to take such actions (including the making of, or refraining from making, any relevant elections) to perfect such status. The Partners further intend that the provisions of sections 6221-6234 of the Code shall apply to the Partnership and intend that, if the circumstances so require, an election under section 6231(a)(1)(B)(ii6231(a)(l)(B)(ii) of the Code shall be made. The Board shall have authority to amend or supplement the provisions of this Section 6.4 from time to time, as it sees fit.
Appears in 1 contract
Partnership Tax Status. The Partners intend that the Partnership shall be treated as a partnership for U.S. Federal, state and local income tax purposes and hereby agree, and authorize the Partnership and the Tax Matters Partner to take such actions (including the making of, or refraining retraining from making, any relevant elections) to perfect such status. The Partners further intend that the provisions of sections 6221-6234 of the Code shall apply to the Partnership and intend that, if the circumstances so require, an election under section 6231(a)(1)(B)(ii) of the Code shall be made. The Board shall have authority to amend or supplement the provisions of this Section 6.4 from time to time, as it sees fit.
Appears in 1 contract
Samples: Limited Partnership Agreement (Delta Energy Center, LLC)
Partnership Tax Status. The Partners intend that the Partnership shall be treated as a partnership for U.S. Federal, state and local income tax purposes and hereby agree, and authorize the Partnership and the Tax Matters Partner to take such actions (including the making of, or refraining from making, any relevant elections) to perfect such status. The Partners further intend that the provisions of sections 6221-6234 of the Code shall apply to the Partnership and intend that, if the circumstances so require, an election under section 6231(a)(1)(B)(ii623l(a)(1)(B)(ii) of the Code shall be made. The Board shall have authority to amend or supplement the provisions of this Section 6.4 from time to time, as it sees fit.
Appears in 1 contract