Prohibition Against Publicly Traded Partnership. The Manager shall take all action necessary to prevent the Company from qualifying as a publicly traded partnership within the meaning of Code Section 7704, including, without limitation, limiting the number of Members to less than 500 in compliance with the safe harbor under IRS Notice 88-75.
Appears in 6 contracts
Samples: Operating Agreement (Wellsford Real Properties Inc), Operating Agreement (Wellsford Real Properties Inc), Operating Agreement (Wellsford Real Properties Inc)
Prohibition Against Publicly Traded Partnership. The Manager shall take all action necessary to prevent the Company from qualifying as a publicly traded partnership within with the meaning of Code Section 7704, including, without limitation, limiting the number of Members to less than 500 in compliance with the safe harbor under IRS Notice 88-75.
Appears in 2 contracts
Samples: Operating Agreement (Strategic Realty Trust, Inc.), Operating Agreement (Strategic Realty Trust, Inc.)
Prohibition Against Publicly Traded Partnership. The Manager Managers shall take all action necessary to prevent the Company from qualifying as a publicly traded partnership within with the meaning of Code Section 7704and Regulations, including, without limitation, limiting the number of Members to less than 500 in compliance with the safe harbor under IRS Notice 88-75500.
Appears in 1 contract
Samples: Operating Agreement (Prospect Global Resources Inc.)
Prohibition Against Publicly Traded Partnership. The Manager shall take all action necessary to prevent the Company from qualifying as a publicly traded partnership within the meaning of Code Section 7704, including, without limitation, limiting 7704 of the number of Members to less than 500 in compliance with the safe harbor under IRS Notice 88-75Code.
Appears in 1 contract
