Common use of Special Allocations with Respect to Contributed or Revalued Property Clause in Contracts

Special Allocations with Respect to Contributed or Revalued Property. If a Member contributes property to the LLC which has a difference between its tax basis and its fair market value on the date of its contribution, then all items of income, gain, loss, and deduction with respect to such contributed property shall be determined and allocated among the Members, and the Capital Accounts of the Members shall be determined in accordance with Section 704(c) of the Code, the Treasury Regulations thereunder, and Section 1.704-1(b) of the Treasury Regulations, so as to take into account the variation between the tax basis and fair market value of such property at the time of its contribution. Furthermore, in the case of any required or optional revaluation of LLC property and corresponding adjustment of Capital Accounts, taxable income, gain, loss, and deduction with respect to such property shall be allocated among the Members in a manner that takes into account any variation between the adjusted tax basis of such property and its book value in the same manner as variations between tax basis and fair market value are taken into account under Section 704(c) of the Code in determining income, gain, loss,