Special Allocations Pursuant to Section 704 Sample Clauses

Special Allocations Pursuant to Section 704. (c). Notwithstanding the foregoing provisions of this Article, pursuant to the requirements of Section 704(c) of the Code and any Treasury Regulations promulgated thereunder, income, gain, loss and deduction with respect to any asset contributed to the Company by any Member shall be allocated, for tax purposes only, among the Members so as to take account of the variation between the adjusted tax basis of such asset to the Company and its Book Value computed in accordance with the definition of Book Value set forth in Article 1. In accordance with the Treasury Regulations promulgated under Section 704(b) of the Code, in the event the Book Value of any Company asset is subsequently adjusted in accordance with the last sentence of such definition of Book Value, subsequent allocations of income, gain, loss and deduction with respect to such asset shall take account of any variation between the adjusted tax basis of the asset to the Company and its Book Value in the same manner as under Code Section 704(c) and any Treasury Regulations promulgated thereunder.
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