Common use of Purpose and Application Clause in Contracts

Purpose and Application. The purpose and the intent of the special allocations provided for in this Section 5.3 are to comply with the provisions of Regulations sectionl.704-1(b) and sectionl.704-2, and such special allocations are to be made so as to accomplish that result. However, to the extent possible, the Members in allocating items of income, gain, loss, or deduction among the Members shall take into account the special allocations in such a manner that the net amount of allocations to each Member shall be the same as such Member's distributive share of Profits and Losses would have been had the events requiring the special allocations not taken place. The Members shall apply the provisions of this Section 5.3 in whatever order they reasonably believe will minimize any economic distortion that otherwise might result from the application of the special allocations.

Purpose and Application. The purpose and the intent of the special allocations provided for in Section 6.3 of the Agreement and Sections 1.2(a) through (g) of this Section 5.3 Appendix are to comply with the provisions of Regulations sectionl.704Sections 1.704-1(b) and sectionl.7041.704-2, and such special allocations are to be made so as to accomplish that result. However, to the extent possible, the Members Board, in allocating items of income, gain, loss, or deduction among the Members Members, shall take into account the special allocations in such a manner that the net amount of allocations to each Member shall be the same as such Member's ’s distributive share of Profits and Losses would have been had the events requiring the special allocations not taken place. The Members Board shall apply the provisions of this Section 5.3 in whatever order they the Board reasonably believe believes will minimize any economic distortion that otherwise might result from the application effect of the special allocations.

Purpose and Application. The purpose and the intent of the special allocations provided for in this Section 5.3 Sections 9.1(c), (d), and (g) are to comply with the provisions of Regulations sectionl.704sections 1.704-1(bl(b) and sectionl.7041.704-22 of the Income Tax Regulations, and such special allocations are to be made so as to accomplish that result. However, to the extent possible, the Members in allocating items of income, gain, loss, or deduction among the Members shall take into account the special allocations in such a manner that the net amount of allocations to each Member shall be the same as such Member's distributive share of Profits and Losses would have been had the events requiring the special allocations not taken place. The Members shall apply the provisions of this Section 5.3 9.1 in whatever order they reasonably believe will minimize any economic distortion that otherwise might result from the application of the special allocations.

Purpose and Application. The purpose and the intent of the special allocations provided for in Section 6.3 of the Agreement and Sections 1.2(a) through (g) of this Section 5.3 Appendix are to comply with the provisions of Regulations sectionl.704Sections 1.704-1(b) and sectionl.7041.704-2, and such special allocations are to be made so as to accomplish that result. However, to the extent possible, the Members Management Board, in allocating items of income, gain, loss, or deduction among the Members Members, shall take into account the special allocations in such a manner that the net amount of allocations to each Member shall be the same as such Member's ’s distributive share of Profits and Losses would have been had the events requiring the special allocations not taken place. The Members Management Board shall apply the provisions of this Section 5.3 in whatever order they the Management Board reasonably believe believes will minimize any economic distortion that otherwise might result from the application effect of the special allocations.

Purpose and Application. The purpose and the intent of the special allocations provided for in Section 6.3 of the Agreement and Sections 1.2(a) through (g) of this Section 5.3 Appendix are to comply with the provisions of Regulations sectionl.704Sections 1.704-1(b) and sectionl.7041.704-2, and such special allocations are to be made so as to accomplish that result. However, to the extent possible, the Members Manager, in allocating items of income, gain, loss, or deduction among the Members Members, shall take into account the special allocations in such a manner that the net amount of allocations to each Member shall be the same as such Member's ’s distributive share of Profits and Losses would have been had the events requiring the special allocations not taken place. The Members Manager shall apply the provisions of this Section 5.3 in whatever order they the Manager reasonably believe believes will minimize any economic distortion that otherwise might result from the application effect of the special allocations.

Purpose and Application. The purpose and the intent of the special allocations provided for in Section 6.3 of the Agreement and Sections 1.2(a) through (g) of this Section 5.3 Appendix are to comply with the provisions of Regulations sectionl.704Sections l.704-1(b) and sectionl.704l.704-2, and such special allocations are to be made so as to accomplish that result. However, to the extent possible, the Members Board, in allocating items of income, gain, loss, or deduction among the Members Members, shall take into account the special allocations in such a manner that the net amount of allocations to each Member shall be the same as such Member's ’s distributive share of Profits and Losses would have been had the events requiring the special allocations not taken place. The Members Board shall apply the provisions of this Section 5.3 in whatever order they the Board reasonably believe believes will minimize any economic distortion that otherwise might result from the application effect of the special allocations.

Purpose and Application. The purpose and the intent of the special ----------------------- allocations provided for in this Section 5.3 are to comply with the provisions of Regulations sectionl.704Regulation Sections 1.704-1(b) and sectionl.7041.704-2, and such special allocations are to be made so as to accomplish that result. However, to the extent possible, the Members Managing Member, in allocating items of income, gain, loss, or deduction among the Members Members, shall take into account the special allocations in such a manner that the net amount of allocations to each Member shall be the same as such Member's distributive share of Profits and Losses would have been had the events requiring the special allocations not taken place. The Members Managing Member shall apply the provisions of this Section 5.3 in whatever order they the Managing Member reasonably believe will minimize any economic distortion that otherwise might result from the application effect of the special allocations.

Purpose and Application. The purpose and the intent of the special allocations provided for in Section 6.3 of the Agreement and Sections 1.2(a) through (g) of this Section 5.3 Appendix are to comply with the provisions of Regulations sectionl.704Sections 1.704-1(b) and sectionl.7041.704-2, and such special allocations are to be made so as to accomplish that result. However, to the extent possible, the Members Managers, in allocating items of income, gain, loss, or deduction among the Members Members, shall take into account the special allocations in such a manner that the net amount of allocations to each Member shall be the same as such Member's distributive share of Profits and Losses would have been had the events requiring the special allocations not taken place. The Members Managers shall apply the provisions of this Section 5.3 in whatever order they the Managers reasonably believe will minimize any economic distortion that otherwise might result from the application effect of the special allocations.

Purpose and Application. The purpose and the intent of the special allocations provided for in Section 6.3 of the Agreement and Sections 1.2(a) through (g) of this Section 5.3 Appendix are to comply with the provisions of Regulations sectionl.704Sections 1.704-1(b) and sectionl.7041.704-2, and such special allocations are to be made so as to accomplish that result. However, to the extent possible, the Members Manager, in allocating items of income, gain, loss, or deduction among the Members Members, shall take into account the special allocations in such a manner that the net amount of allocations to each Member shall be the same as such Member's distributive share of Profits and Losses would have been had the events requiring the special allocations not taken place. The Members Manager shall apply the provisions of this Section 5.3 in whatever order they the Manager reasonably believe believes will minimize any economic distortion that otherwise might result from the application effect of the special allocations.