Special Tax Audit Allocations. Notwithstanding anything contained in this Agreement to the contrary, in the event that the federal taxable income of the Program (or any item thereof) is adjusted as the result of an audit by the Service, the Partners’ Capital Accounts shall be adjusted in a manner that reflects the adjustments as though corresponding book adjustments had been originally reflected in the Net Profits or Net Losses of the Program determined pursuant to Section 6.1.
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Special Tax Audit Allocations. Notwithstanding anything contained in this Agreement to the contrary, in the event that the federal taxable income of the Program Partnership for federal income tax purposes (or any item thereof) is adjusted as the result of an audit by the Internal Revenue Service, the Partners’ ' Capital Accounts shall be adjusted in a manner that which reflects the such adjustments as though corresponding book adjustments had been originally reflected in the Net Book Profits or Net Book Losses of the Program Partnership determined pursuant to Section 6.1the terms of this Agreement.
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Special Tax Audit Allocations. Notwithstanding anything contained in this Agreement to the contrary, in the event that the federal taxable income of the Program Partnership for Federal income tax purposes (or any item thereof) is adjusted as the result of an audit by the Internal Revenue Service, the Partners’ Capital Accounts shall be adjusted in a manner that which reflects the such adjustments as though corresponding book adjustments had been originally reflected in the Net Book Profits or Net Book Losses of the Program Partnership determined pursuant to Section 6.1the terms of this Agreement.
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Samples: Limited Partnership Agreement (Indigo-Energy, Inc.)
Special Tax Audit Allocations. Notwithstanding anything contained in this Agreement to the contrary, in the event that the federal taxable income of the Program Partnership (or any item thereof) is adjusted as the result of an audit by the Service, the Partners’ Capital Accounts shall be adjusted in a manner that reflects the adjustments as though corresponding book adjustments had been originally reflected in the Net Profits or Net Losses of the Program Partnership determined pursuant to Section 6.1.
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