Common use of Profits for Tax Purposes from a Capital Transaction Clause in Contracts

Profits for Tax Purposes from a Capital Transaction. The Profits for Tax Purposes of the Partnership arising from a Capital Transaction shall be allocated as follows: First, to the class comprised of the Investor Limited Partners to the extent of cash distributions pursuant to Section 8.3(a) First attributable to the return of Invested Capital; Second, to the class comprised of the Investor Limited Partners to the extent of cash distributions pursuant to Section 8.3(a) Second attributable to payment of the Cumulative Return on Investment; Third, to the classes comprised of the Original Limited Partner and the General Partners to the extent of cash distributions pursuant to Section 8.3(a) Third attributable to the return of Invested Capital; and