Special Allocations of Partner Nonrecourse Deductions. Notwithstanding any other provision in this Agreement, in compliance with applicable Treasury Regulations, including Treasury Regulation Section 1.704-2, allocations of Partner Nonrecourse Deductions shall be made among the Partners in accordance with the ratios in which the Partners (or the affiliates of any Partners) share the economic risk of loss with respect to the Partner Nonrecourse Liabilities to which such Partner Nonrecourse Deductions are attributable.
Appears in 2 contracts
Samples: Limited Partnership Agreement (Indigo-Energy, Inc.), Partnership Agreement (84 Financial, L.P.)
Special Allocations of Partner Nonrecourse Deductions. Notwithstanding any other provision in this Agreementof Section 6.2, Section6 5.(a) and Section 6.5(b), in compliance with applicable Treasury Regulations, including Treasury Regulation Section § 1.704-22(b), allocations of Partner Nonrecourse Deductions shall be made among between the Partners in accordance with the ratios in which the Partners (or the their affiliates of any Partners) share the economic risk of loss with respect to the Partner Nonrecourse Liabilities to which such the Partner Nonrecourse Deductions are attributable.
Appears in 1 contract
Special Allocations of Partner Nonrecourse Deductions. Notwithstanding any other provision in this Agreementof Section 6.2, Section 6.5(a) and Section 6.5(b), in compliance with applicable Treasury Regulations, including Treasury Regulation Section § 1.704-22(b), allocations of Partner Nonrecourse Deductions shall be made among the Partners in accordance with the ratios in which the Partners (or the their affiliates of any Partners) share the economic risk of loss with respect to the Partner Nonrecourse Liabilities to which such the Partner Nonrecourse Deductions are attributable.
Appears in 1 contract