Preventative Allocation. If any Limited Partner would have a deficit Capital Account balance at the end of any taxable year which is in excess of the sum of (i) the amount such Limited Partner is obligated to restore to the Partnership on liquidation, (ii) such Limited Partner’s share of the Partnership’s Minimum Gain as of the end of such taxable year, and (iii) such Limited Partner’s share of Partner Minimum Gain as of the end of such taxable year, each such Limited Partner will be specially allocated items of Partnership income and gain in the amount of such excess as quickly as possible. Allocations under this Section 2(d) will be comprised of a pro rata portion of each item of Partnership income (including gross income) and gain for the taxable year.
Appears in 8 contracts
Samples: Limited Partnership Agreement (Safeway Stores 42, Inc.), Limited Partnership Agreement (Safeway Stores 42, Inc.), Limited Partnership Agreement (Safeway Stores 42, Inc.)
