Common use of Revaluations Clause in Contracts

Revaluations. Notwithstanding Section 6.4.A hereof, Tax Items with respect to Property that is contributed to the Company with a Gross Asset Value that varies from its basis in the hands of the contributing Member immediately preceding the date of contribution shall be allocated among the Members for income tax purposes pursuant to any method permitted under Regulations Section 1.704-3 as may be selected by the Managing Member, in its sole and absolute discretion. In the event that the Gross Asset Value of any Company asset is adjusted pursuant to subsection (b) of the definition of "Gross Asset Value" (provided in Article 1 hereof), subsequent allocations of Tax Items with respect to such asset shall take account of the variation, if any, between the adjusted basis of such asset and its Gross Asset Value in the same manner as under Code Section 704(c) and the applicable Regulations and this Section 6.4.B., pursuant to any method permitted under Regulations Section 1.704-3 as selected by the Managing Member in its sole and absolute discretion.

Revaluations. Notwithstanding Section 6.4.A hereof, Tax Items with respect to Property that is contributed to the Company with a Gross Asset Value that varies from its basis in the hands of the contributing Member immediately preceding the date of contribution shall be allocated among the Members for income tax purposes pursuant to any method permitted under the “traditional method” as described in Regulations Section 1.704-3 as may be selected by the Managing Member, in its sole and absolute discretion3(b). In the event that the Gross Asset Value of any Company asset is adjusted pursuant to subsection (b) of the definition of "“Gross Asset Value" ” (provided in Article 1 I hereof), subsequent allocations of Tax Items with respect to such asset (other than Tax Items governed by the previous sentence) shall take account of the variation, if any, between the adjusted basis of such asset and its Gross Asset Value in the same manner as under Code Section 704(c) and the applicable Regulations and this Section 6.4.B.6.4.B, pursuant to any method permitted under Regulations Section 1.704-3 as selected by the Managing Member in its sole and absolute discretionMember.

Revaluations. Notwithstanding Section 6.4.A hereof, Tax Items with respect to Property that is contributed to the Company with a Gross Asset Value that varies from its basis in the hands of the contributing Member immediately preceding the date of contribution shall be allocated among the Members for income tax purposes pursuant to any method permitted under the "traditional method" as described in Regulations Section 1.704-3 as may be selected by the Managing Member, in its sole and absolute discretion3(b). In the event that the Gross Asset Value of any Company asset is adjusted pursuant to subsection (b) of the definition of "Gross Asset Value" (provided in Article 1 hereof), subsequent allocations of Tax Items with respect to such asset shall take account of the variation, if any, between the adjusted basis of such asset and its Gross Asset Value in the same manner as under Code Section 704(c) and the applicable Regulations and this Section 6.4.B., pursuant to any method permitted under Regulations Section 1.704-3 1.704 -3 as selected by the Managing Member in its sole and absolute discretion.Member

Revaluations. Notwithstanding Section 6.4.A hereof, Tax Items with respect to Property that is contributed to the Company with a Gross Asset Value that varies from its basis in the hands of the contributing Member immediately preceding the date of contribution shall be allocated among the Members for income tax purposes pursuant to any method permitted under the "traditional method" as described in Regulations Section 1.704-3 as may be selected by the Managing Member, in its sole and absolute discretion3(d). In the event that the Gross Asset Value of any Company asset is adjusted pursuant to subsection (b) of the definition of "Gross Asset Value" (provided in Article 1 hereof), subsequent allocations of Tax Items with respect to such asset shall take account of the variation, if any, between the adjusted basis of such asset and its Gross Asset Value in the same manner as under Code Section 704(c) and the applicable Regulations and this Section 6.4.B., pursuant to any method permitted under Regulations Section 1.704-3 as selected by the Managing Member in its sole and absolute discretion.Member

Revaluations. Notwithstanding Section 6.4.A hereof, Tax Items with respect to Property that is contributed to the Company with a Gross Asset Value that varies from its basis in the hands of the contributing Member immediately preceding the date of contribution shall be allocated among the Members for income tax purposes pursuant to any method permitted under the "traditional method" as described in Regulations Section 1.704-3 as may be selected by the Managing Member, in its sole and absolute discretion3(b). In the event that the Gross Asset Value of any Company asset is adjusted pursuant to subsection (b) of the definition of "Gross Asset Value" (provided in Article 1 hereof), subsequent allocations of Tax Items with --------- respect to such asset shall take account of the variation, if any, between the adjusted basis of such asset and its Gross Asset Value in the same manner as under Code Section 704(c) and the applicable Regulations and this Section 6.4.B.6.4.B, pursuant to any method permitted under Regulations Section 1.704-3 as selected by the Managing Member in its sole and absolute discretion.Member

Revaluations. Notwithstanding Section 6.4.A 6.7.A hereof, Tax Items with respect to Property Partnership property that is contributed to the Company with Partnership by a Gross Asset Value that varies from its basis in the hands of the contributing Member immediately preceding the date of contribution Partner shall be allocated shared among the Members Partners for income tax purposes pursuant to any method permitted Regulations promulgated under Regulations Section 1.704-3 704(c) of the Code, so as may be selected by to take into account the Managing Membervariation, in if any, between the adjusted tax basis of the property to the Partnership and its sole and absolute discretioninitial Gross Asset Value. In the event that the Gross Asset Value of any Company Partnership asset is adjusted pursuant to subsection subparagraph (b) of the definition of "Gross Asset Value" Value (provided in Article 1 hereofof this Agreement), subsequent allocations of Tax Items with respect to such asset shall take account of the variation, if any, between the adjusted basis of such asset and its Gross Asset Value in the same manner as under Code Section 704(c) of the Code and the applicable Regulations and this Section 6.4.B., pursuant to any method permitted under regulations consistent with the requirements of Regulations Section 1.704-3 1(b)(2)(iv)(g) using any method approved under 704(c) of the Code and the applicable regulations as selected chosen by the Managing Member in its sole and absolute discretionGeneral Partner.