Partnership Tax Treatment. It is the intention of the Members that the Company be treated as a partnership for Federal, state and local income tax purposes, and the Interest Holders shall not take any position or make any election, in a tax return or otherwise, inconsistent with such treatment.
Appears in 12 contracts
Samples: Limited Liability Company Agreement (Triad of Oregon, LLC), Limited Liability Company Agreement (Triad of Oregon, LLC), Limited Liability Company Agreement (Hospital of Fulton, Inc.)
Partnership Tax Treatment. It is the intention of the The Members expect and intend that the Company shall be treated as a partnership for Federal, all federal and state and local income tax purposes, and the Interest Holders shall not Members agree that they will not: (a) take a position on any position federal, state, local or make any electionother tax return, in or otherwise assert a tax return or otherwiseposition, inconsistent with such treatmentexpectation and intent; or (b) elect for the Company to be treated as an association for tax purposes or do any other act or thing which could cause the Company to be treated as other than a partnership for federal income tax purposes.
Appears in 4 contracts
Samples: Operating Agreement (Patriot Scientific Corp), Operating Agreement (Patriot Scientific Corp), Master Agreement (Patriot Scientific Corp)
Partnership Tax Treatment. It is the intention of the Members that the Company be treated as a partnership for Federal, state and local income tax purposes, and the Interest Holders Members shall not take any position or make any election, in a tax return or otherwise, inconsistent with such treatment. The Members shall cause the Company to file the appropriate forms with the Internal Revenue Service to elect partnership status.
Appears in 2 contracts
Samples: Operating Agreement (Atria Communities Inc), Operating Agreement (Atria Communities Inc)
Partnership Tax Treatment. It is the intention of the Members that the Company be treated as a partnership for Federal, state and local income tax purposes, and the Interest Holders Members shall not take any position or make any election, in a tax return or otherwise, inconsistent with such treatment.
Appears in 2 contracts
Samples: Operating Agreement, Operating Agreement (First Savings Financial Group Inc)
Partnership Tax Treatment. It is the intention of the Members that the Company be treated as a partnership for Federal, state and local income tax purposes, and the Interest Holders Members shall not take any position or make any election, in a tax return or otherwise, inconsistent with such treatment.such
Appears in 1 contract