Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 4 contracts
Samples: Duke Realty Limited Partnership/, Duke Realty Limited Partnership/, Duke Realty Limited Partnership/
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Section 1.704-l(b)(2)(iv)(m1(b)(2)(iv)(m) of the Treasury Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section section of the Treasury Regulations.
Appears in 4 contracts
Samples: Limited Partnership Agreement (Jamestown Invest 1, LLC), Limited Partnership Agreement (Jamestown Invest 1, LLC), Limited Partnership Agreement (Jamestown Atlanta Invest 1, LLC)
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) ), and such item of gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 4 contracts
Samples: Gotham Golf Corp, Capstar Hotel Co, Gotham Golf Corp
Section 754 Adjustments. To the extent an adjustment to the ----------------------- adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) of the Code or Section 743(c) of the Code Section 743(b) is required, pursuant to Treasury Regulations Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Adjusted Capital Accounts are required to be adjusted pursuant to such Treasury Regulations Section of the Treasury Regulations1.704-1(b)(2)(iv)(m).
Appears in 3 contracts
Samples: Cencom Cable Entertainment Inc /New, Cencom Cable Entertainment Inc /New, Cencom Cable Entertainment Inc /New
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) ), and such item of gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 3 contracts
Samples: Sl Green Realty Corp, Sl Green Realty Corp, Camden Property Trust
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code (including any such adjustments pursuant to Regulations Section 743(b1.734-2(b)(1)) is required, pursuant to Section Regulations Sections 1.704-l(b)(2)(iv)(m) of the Treasury Regulations1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners and Interest Holders in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 2 contracts
Samples: OCI Resources LP, OCI Resources LP
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Section 1.704-l(b)(2)(iv)(m1(b)(2)(iv)(m) of the Treasury Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 2 contracts
Samples: Agreement (Advanced Prosthetics of America, Inc.), JMA Associates, Inc.
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to under Code Section section 734(b) or Code Section section 743(b) is required, pursuant to Section 1.704-l(b)(2)(iv)(msection 1.704- 1(b)(2)(iv)(m) of the Treasury Regulations, to be taken into account in determining Capital Accounts, the amount of such the adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the tax basis of the asset) or loss (if the adjustment decreases such basisthe tax basis of the asset) and such that gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such that Section of the Treasury Regulations.
Appears in 2 contracts
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Treas. Reg. Section 1.704-l(b)(2)(iv)(m1(b)(2)(iv) of the Treasury Regulations(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases increase the basis of the asset) asset or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulationssection.
Appears in 2 contracts
Samples: Atlas Pipeline Holdings, L.P., Atlas Pipeline Partners Lp
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) , and such item of gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 2 contracts
Samples: Fourth (Gables Realty Limited Partnership), Fourth (Gables Residential Trust)
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) of the Code or Code Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 1 contract
Samples: General Public Utilities Corp /Pa/
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Section Sections 1.704-l(b)(2)(iv)(m1(b)(2)(iv)(m)(2) or (4) of the Treasury Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 1 contract
Section 754 Adjustments. To the extent that the Partnership makes an election pursuant to Code section 754, the amount of any adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section section 734(b) or Code Section 743(b) that is required, pursuant to Section Regulations section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) the basis of the asset), and such the gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury RegulationsRegulations section.
Appears in 1 contract
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, to be taken in account in maintaining Capital Accounts pursuant to Section 4.10 and Treasury Regulation § 1.704-l(b)(2)(iv)(m) of the Treasury Regulations, to be taken into account in determining Capital Accounts1(b)(2)(iv)(m), the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) asset or as an item of loss (if the adjustment decreases such basis) and such . Such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are Account or adjustments required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 1 contract
Samples: Limited Partnership Agreement (Atlantic Oklahoma Wind, LLC)
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Section Treas. Regs. § 1.704-l(b)(2)(iv)(m) of the Treasury Regulations1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 1 contract
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Section 1.704-l(b)(2)(iv)(m1(b)(2)(iv)(m) of the Treasury Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 1 contract
Samples: Duke Realty Investments Inc
Section 754 Adjustments. To the extent an adjustment to the ----------------------- adjusted tax basis of any Partnership asset pursuant to under Code Section section 734(b) or Code Section section 743(b) is required, pursuant to Section section 1.704-l(b)(2)(iv)(m1(b)(2)(iv)(m) of the Treasury Regulations, to be taken into account in determining Capital Accounts, the amount of such the adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the tax basis of the asset) or loss (if the adjustment decreases such basisthe tax basis of the asset) and such that gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such that Section of the Treasury Regulations.
Appears in 1 contract
Samples: Hob Entertainment Inc /De/
Section 754 Adjustments. To Pursuant to Treasury ------------------------- Regulations section 1.704-1 (b)(2)(iv)(m), to the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to under Code Section section 732, 734(b) or Code Section 743(b) is required, pursuant to Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations, required to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section section of the Treasury Regulations.
Appears in 1 contract
Samples: Limited Partnership Agreement (Horton D R Inc /De/)
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Regulations Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the General Partner and Limited Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 1 contract
Samples: Lexreit Properties Inc
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Section 1.704-l(b)(2)(iv)(mRegulations Sections 1.704- 1(b)(2)(iv)(m)(2) of the Treasury Regulationsor (4), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 1 contract
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset property pursuant to Code Section Sections 734(b) or Code Section 743(b) of the Code is required, pursuant to Treasury Regulations Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall will be treated as an item of gain (if the adjustment increases the basis of the assetproperty) or loss (if the adjustment decreases such basisproperty) and such gain or loss shall will be specially allocated to among the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Treasury Regulations Section of the Treasury Regulations1.704- 1(b)(2)(iv)(m).
Appears in 1 contract
Samples: Limited Partnership Agreement (Stratus Properties Inc)
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) of the Code or Code Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 1 contract
Samples: Limited Partnership Agreement (Atlantic Oklahoma Wind, LLC)
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b734 (b) or Code Section 743(b743 (b) is required, pursuant to Regulations Section 1.704-l(b)(2)(iv)(m1 (b) of the Treasury Regulations(2) (iv) (m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 1 contract
Samples: Detroit Radio, LLC
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) of the Code or Section 743(c) of the Code Section 743(b) is required, pursuant to Treasury Regulations Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Treasury Regulations Section of the Treasury Regulations1.704-1(b)(2)(iv)(m).
Appears in 1 contract
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Section 1.7041 .704-l(b)(2)(iv)(m) of the Treasury Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 1 contract
Samples: Duke Realty Limited Partnership/
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Section Sections 1.704-l(b)(2)(iv)(m1(b)(2)(iv)(M)(2) or (4) of the Treasury Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 1 contract
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) ), and such item of gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations. 64 2.
Appears in 1 contract
Section 754 Adjustments. To the extent that an adjustment adjust to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations, required to be taken into account account, pursuant to Regulations Section 1.704-1(b)(2)(iv)(m), in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the tax basis of the asset) or loss (if the adjustment decreases such basis) the tax basis of the asset), and such gain or loss shall be specially allocated to the Partners in a manner consistent accordance with the manner in which their Capital Accounts are required to be adjusted pursuant to such Regulations Section of the Treasury Regulations1.704-1(b)(2)(iv)(m).
Appears in 1 contract
Samples: Limited Partnership Agreement (Concepts Direct Inc)
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset Property is required pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to and Regulations Section 1.704-l(b)(2)(iv)(m1(b)(2)(iv)(m)(2) of the Treasury Regulationsor (4), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the assetsuch Partnership Property) or loss (if the adjustment decreases such basis) ), and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Code Sections and Regulations.
Appears in 1 contract
Samples: Insignia Properties Trust /
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or 743(c) of the Code Section 743(b) is required, pursuant to Treasury Regulation Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) ), and such item of gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 1 contract
Samples: Suburban Propane Partners Lp
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Treasury Regulation Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section section of the Treasury Regulations.
Appears in 1 contract
Samples: Limited Partnership Agreement (Iroquois Gas Transmission System Lp)
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) of the Code or Code Section 743(b) of the Code is required, pursuant to Regulations Section 1.704-l(b)(2)(iv)(m1(b) of the Treasury Regulations(2) (iv) (m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 1 contract
Samples: Limited Partnership Agreement (Atlantic Oklahoma Wind, LLC)
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset Property pursuant to Code Section Sections 734(b) or Code Section 743(b) of the Code is required, pursuant to Section 1.704-l(b)(2)(iv)(m1(b)(2)(iv)(m) of the Treasury Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall will be treated as an item of gain (if the adjustment increases the basis of the assetProperty) or loss (if the adjustment decreases such basis) and such gain or loss shall will be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury Regulations.
Appears in 1 contract
Samples: Limited Partnership Agreement (VOC Brazos Energy Partners, LP)
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section Sec. 734(b) or Code Section Sec. 743(b) is required, pursuant to Section Treas. Reg. Sec. 1.704-l(b)(2)(iv)(m) of the Treasury Regulations1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases increase the basis of the asset) asset or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section of the Treasury RegulationsSection.
Appears in 1 contract
Samples: MCN Corp
Section 754 Adjustments. To the extent that an adjustment to the adjusted tax basis of any Partnership asset pursuant to in accordance with Code Section 734(b) or Code Section 743(b) is required, required pursuant to Treasury Regulations Section 1.704-l(b)(2)(iv)(m1(b)(2)(iv)(m) of the Treasury Regulations, to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such Section sections of the Treasury Regulations.
Appears in 1 contract
Samples: Limited Partnership Agreement (Colony Capital, Inc.)
Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Partnership asset pursuant to Code Section 734(b) or Code Section 743(b) is required, pursuant to Treasury Regulation Section 1.704-l(b)(2)(iv)(m) of the Treasury Regulations1(b)(2)(iv)(m), to be taken into account in determining Capital Accounts, the amount of such adjustment to the Capital Accounts shall be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such basis) and such gain or loss shall be specially allocated to the Partners in a manner consistent with the manner in which their Capital Accounts are required to be adjusted pursuant to such said Section of the Treasury Regulations.
Appears in 1 contract
Samples: Limited Partnership Agreement (Barnwell Industries Inc)