Partnership Tax Treatment. The Members intend that the Company be treated as a partnership for federal, state and local income tax purposes and the Company and each Member shall file all tax returns on the basis consistent therewith. Specifically, the Members intend that the Company shall not be a partnership (including, without limitation, a limited partnership) or joint venture and that no Interest Holder shall be a partner or joint venturer of any other Interest Holder for any purposes other than federal, state and local tax purposes, and this Agreement shall not be construed to suggest otherwise.
Appears in 2 contracts
Samples: Limited Liability Company Agreement (Zugel Christian), Limited Liability Company Agreement (Zugel Christian)
Partnership Tax Treatment. 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 Company and each Member shall file all tax returns on the basis consistent therewith. Specifically, the Members intend that the Company shall not be a partnership (including, without limitation, a limited partnership) or joint venture and that no Interest Holder shall be a partner or joint venturer of any other Interest Holder for any purposes other than federal, state and local tax purposes, and this Agreement shall not the Members agree that they will not: (a) take a position on any federal, state, local or other tax return, or otherwise assert a position, inconsistent with such expectation and intent; or (b) elect for the Company to be construed treated as an association taxable as a corporation for tax purposes or do any other act or thing which could cause the Company to suggest otherwisebe treated as other than a partnership for federal income tax purposes.
Appears in 1 contract
Samples: Limited Liability Company Operating Agreement (Ignite Restaurant Group, Inc.)
Partnership Tax Treatment. The Members expect and intend that the Company shall be treated as a partnership for federal, state and local all federal income tax purposes and the Company and each Member shall file all tax returns on the basis consistent therewith. Specifically, the Members intend that the Company shall not be a partnership (including, without limitation, a limited partnership) or joint venture and that no Interest Holder shall be a partner or joint venturer of any other Interest Holder for any purposes other than federal, state and local tax purposes, and this Agreement shall not the Members agree that they will not: (i) take a position on any federal, state, local or other tax return or otherwise assert a position, inconsistent with such expectation and intent; or (ii) do any act or thing which could cause the Company to be construed to suggest otherwisetreated as other than a partnership for federal income tax purposes.
Appears in 1 contract
Samples: Operating Agreement (Championship Auto Racing Teams Inc)