Common use of Section 754 Adjustments Clause in Contracts

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Section 734(b) or Section 743 (b) of the Code is required pursuant to Treasury Regulation Section 1.70401(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the Member’s Interest in the Company, 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 specially allocated to the Members in accordance with their Interests in the Company in the event Treasury Regulation Section 1.704(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad made in the event Treasury Regulation Section 1.704-l(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Section 1.70401(b)(2)(iv)(m)(2Regulations §1.704-1(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest interest in the Company, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Section 1.704(b)(2)(iv)(m)(2Regulations §1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Section Regulations §1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company Fund asset pursuant to Code Section 734(b) or Code Section 743 (b743(b) of the Code is required pursuant to Treasury Regulation Section 1.70401(b)(2)(iv)(m)(2Regulations §1.704-1(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4Treasury Regulations §1.704- 1(b)(2)(iv)(m)(4) to be taken into account in determining Capital Accounts as the result of a distribution to a Member Partner in complete liquidation of the Member’s Interest in the Companyits Fund Interest, 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 specially allocated to the Members Partners in accordance with their Percentage Interests in the Company in the event Treasury Regulation Section 1.704(b)(2)(iv)(m)(2Regulations §1.704-1(b)(2)(iv)(m)(2) applies, or to the Member Partner to whom such distribution wad was made in the event Treasury Regulation Section Regulations §1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest 's interest in the Company, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21. 704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest 's interest in the Company, 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), basis of the asset) and such gain or loss shall be specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Section 743 (b743(b) of the Code is required pursuant to Treasury Regulation Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest interest in the Company, 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 specially allocated to the Members in accordance with their Interests in the Company Section 5.03(a), in the event Treasury Regulation Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.7041(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest interest in the Company, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41.7041(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company LLC asset pursuant to Code Section 734(b) or Code Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Section 1.70401(b)(2)(iv)(m)(2Regulations Sections 1.704-1(b)(2)(4)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) l(b)(2)(4)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the Member’s Interest its interest in the CompanyLLC, 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 Members in accordance with their Interests in the Company LLC in the event that Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704- l(b) (iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event that Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset Property, pursuant to Code Section 734(b) or Code Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest in the CompanyCompany Interest, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or Section 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest 's interest in the Company, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Section under Internal Revenue Code §734(b) or Section 743 (b§743(b) of the Code is required pursuant to under Treasury Regulation Section 1.70401(b)(2)(iv)(m)(2§1.704-1(b)(2)(iv)(m)(2) or §1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the Member’s Interest interest in the Company, the amount of such the 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 the basis), and such the gain or loss shall be specially allocated to the Members in accordance with their Interests interests in the Company in the event that Treasury Regulation Section 1.704(b)(2)(iv)(m)(2§1.704-1(b)(2)(iv)(m)(2) applies, or to the Member Partner to whom such the distribution wad was made in the event that Treasury Regulation Section §1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any asset of the Company asset pursuant to Section 734(b) or Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) (4), to be taken into account in determining Capital Accounts as the result of a distribution Distribution to a Member in complete liquidation of the such Member’s Interest in the CompanyMembership Interests, 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 specially allocated to the Members in accordance with their Interests in the Company Section 6.1 in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, applies or to the Member Members to whom such distribution wad Distribution was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.; and

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Section Code Sections 734(b) or Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Section 1.70401(b)(2)(iv)(m)(2Regulations Sections 1.704-1(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution Distribution to a Member in complete liquidation of the Member’s Interest its interest in the Company, 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 Members in accordance with their Interests interests in the Company in the event if Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad Distribution was made in the event that Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into in account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest interest in the Company, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) 1 (b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest interest in the Company, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Section 743 (b743(b) of the Code is required pursuant to Treasury Regulation Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest interest in the Company, 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 specially allocated to the Members in accordance with their Interests in the Company Section 5.02(a), in the event Treasury Regulation Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Section 1.70401(b)(2)(iv)(m)(2Sections 704-1(b)(2)(iv)(m)(2) or § 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest interest in the Company, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Section 1.704(b)(2)(iv)(m)(2Sections 1.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Section Sections 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Section Code Sections 734(b) or Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Section 1.70401(b)(2)(iv)(m)(2Regulations Sections 1.704-1(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) 1 (b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest interest in the Company, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b) (2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2) (iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest 's interest in the Company, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Section 734(b) or Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest interest in the Company, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset LLC asset, pursuant to Code Section 734(b) or Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or Section 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest 's interest in the CompanyLLC, 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 specially allocated to the Members in accordance with their Interests interests in the Company LLC in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or Section 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest interest in the Company, 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 as an item of loss (if the adjustment decreases such basis), and such gain or loss shall be specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or Section 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest 's interest in the Company, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or Section 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest 's interest in the Company, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset Property, pursuant to Code Section 734(b) or Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or Section 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest interest in the CompanyPlan, the amount of such adjustment to Capital Accounts shall 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 be specially allocated to the Members in accordance with their Interests in the Company Percentage Interest in the event Treasury Regulation Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset asset, pursuant to Code Section 734(b) or Code Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest interest in the Company, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Section 734(b) or Section 743 (b743(b) of the Code is required pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest 's interest in the Company, 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 specially allocated to the Members in accordance with their Interests interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.

Section 754 Adjustments. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Section 734(b) or Section 743 (b743(b) of the Code is required required, pursuant to Treasury Regulation Regulations Section 1.70401(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) or Section 1.704-l(b)(2)(iv)(m)(4) 1(b)(2)(iv)(m)(4), to be taken into account in determining Capital Accounts as the result of a distribution to a Member in complete liquidation of the such Member’s Interest in the Company, 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 specially allocated to the Members in accordance with their Interests in the Company in the event Treasury Regulation Regulations Section 1.704(b)(2)(iv)(m)(21.704-1(b)(2)(iv)(m)(2) applies, or to the Member to whom such distribution wad was made in the event Treasury Regulation Regulations Section 1.704-l(b)(2)(iv)(m)(41(b)(2)(iv)(m)(4) applies.