Common use of Section 754 Adjustments Clause in Contracts

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any C.V. properties pursuant to Code Section 734(b) or Code Section 743(b) is required pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4) to be taken into account in determining capital accounts as the result of a distribution to any Partner in complete liquidation of such Partner’s interest in the C.V., the amount of such adjustment to 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 allocated to the Partners in accordance with Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) if such Treasury Regulation Section applies, or to the Partner to whom such distribution was made if Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any C.V. properties Company asset pursuant to Code Section Sections 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining capital accounts Capital Accounts as the a result of a distribution to any Partner Member in complete or partial liquidation of such PartnerMember’s interest Units in the C.V.Company, the amount of such adjustment to capital accounts 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 allocated to the Partners Members in accordance with Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) if such Treasury Regulation Section applies, applies or to the Partner Member to whom such distribution was made if Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any C.V. properties Company asset pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) or Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining capital accounts Capital Accounts as the result of a distribution to any Partner an Member in complete liquidation of such Partner’s interest in the C.V.his or her interests, the amount of such the adjustment to capital accounts shall Capital Accounts will be treated as an item of gain (if the adjustment increases the basis of the asset) or loss (if the adjustment decreases such that basis) and such that gain or loss shall will be specially allocated to the Partners Members in accordance with their Economic Interests in the event that Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) if such Treasury Regulation Section applies, or to the Partner Member to whom such the distribution was made if Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any C.V. properties Noncash Asset pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Section Regulations Sections 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining capital accounts Capital Accounts as the result of a distribution to any a Partner in complete liquidation of such Partner’s interest in the C.V.Partnership, the amount of such adjustment to capital accounts 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 allocated to the Partners in accordance with Section 6.02(a) in the event that Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(22(b)(2)(iv)(m)(2) if such Treasury Regulation Section applies, or to the Partner to whom such distribution was made if in the event that Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(41.704-(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any C.V. properties Partnership Asset, pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or Section 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining capital accounts Capital Accounts as the result of a distribution Distribution to any a Partner in complete liquidation of such Partner’s interest in the C.V.Partnership, the amount of such adjustment to capital accounts 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 accordance with their interests in the Partnership in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) if such Treasury Regulation Section applies, or to the Partner to whom such distribution Distribution was made if in the event Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any C.V. properties pursuant to Code Section 734(b) or Code Section 743(b) is required pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4) to be taken into account in determining capital accounts as the result of a distribution to any Partner in complete liquidation of such Partner’s interest in the C.V.Units, the amount of such adjustment to 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 allocated to the Partners in accordance with Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) if such Treasury Regulation Section applies, or to the Partner to whom such distribution was made if Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any C.V. properties Company asset pursuant to Code Section Sections 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining capital accounts Capital Accounts as the a result of a distribution to any Partner Member in complete or partial liquidation of such PartnerMember’s interest Units in the C.V.Company, the amount of such adjustment to capital accounts 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 allocated to the Partners Members in accordance with Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) if such Treasury Regulation Section applies, applies or to the Partner Member to whom such distribution was made if Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(4) applies.. (h)

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any C.V. properties Noncash Asset pursuant to Code Section 734(b) or Code Section 743(b) is required required, pursuant to Treasury Regulation Section Regulations Sections 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4) ), to be taken into account in determining capital accounts Capital Accounts as the result of a distribution to any a Partner in complete liquidation of such Partner’s interest in the C.V.Partnership, the amount of such adjustment to capital accounts 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 allocated (i) to the Partners in accordance with Section 6.2(a) as an item comprising Profit or Loss in the event that Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(2) if such Treasury Regulation Section applies, or (ii) to the Partner to whom such distribution was made if in the event that Treasury Regulation Regulations Section 1.704-1(b)(2)(iv)(m)(41.704-(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any C.V. properties Company asset pursuant to Code Section 734(b) or Code Section 743(b) of the Code is required required, pursuant to Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(2) or 1.704-1(b)(2)(iv)(m)(4) of the Treasury Regulations, to be taken into account in determining capital accounts Capital Accounts as the result of a distribution to any Partner a Member in complete liquidation of such Partner’s its interest in the C.V.Company, the amount of such adjustment to capital accounts 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 Members in accordance with Treasury Regulation their respective interests in the Company if Section 1.704-1(b)(2)(iv)(m)(2) if such of the Treasury Regulation Section appliesRegulations is applicable, or to the Partner Member to whom such distribution was made if Treasury Regulation Section 1.704-1(b)(2)(iv)(m)(4) appliesof the Treasury Regulations is applicable.