Common use of TAX ALLOCATIONS AND BOOK ALLOCATIONS Clause in Contracts

TAX ALLOCATIONS AND BOOK ALLOCATIONS. (a) Except as otherwise provided in this Section 6.7, for federal income tax purposes, each item of income, gain, loss and deduction shall, to the extent appropriate, be allocated among the Members in the same manner as its correlative item of “book” income, gain, loss or deduction has been allocated pursuant to the other provisions of this Article VI. (b) In accordance with Code Section 704(c) and the Regulations thereunder, depreciation, amortization, gain and loss, as determined for tax purposes, with respect to any property whose Book Value differs from its adjusted basis for federal income tax purposes shall, for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its Book Value, such allocation to be made by the Approval of the Managers in any manner which is permissible under said Code Section 704(c) and the Regulations thereunder and the Regulations under Code Section 704(b). (c) In the event the Book Value of any property of the Company is subsequently adjusted, subsequent allocations of income, gain, loss and deduction with respect to any such property shall take into account any variation between the adjusted basis of such asset for federal income tax purposes and its respective Book Value in the manner provided under Section 704(c) of the Code and the Regulations thereunder. (d) Allocations pursuant to this Section 6.7 are solely for federal, state, and local income tax purposes, and shall not affect, or in any way be taken into account in computing, any Member’s Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

TAX ALLOCATIONS AND BOOK ALLOCATIONS. (a) Except as otherwise provided in this Section 6.74.7, for federal income tax purposes, each item of income, gain, loss and deduction shall, to the extent appropriate, be allocated among the Members Partners in the same manner as its correlative item of “"book” " income, gain, loss or deduction has been allocated pursuant to the other provisions of this Article VIIV. (b) In accordance with Code Section 704(c) and the Treasury Regulations thereunder, depreciation, amortization, gain and loss, as determined for tax purposes, with respect to any property whose Book Value differs from its adjusted basis for federal income tax purposes shall, for tax purposes, be allocated among the Members Partners so as to take account of any variation between the adjusted basis of such property to the Company Partnership for federal income tax purposes and its Book Value, such allocation to be made by the Approval of the Managers in any manner which is permissible under said Code Section 704(c) and the Treasury Regulations thereunder and the Regulations under Code Section 704(b)thereunder. (c) In the event the Book Value of any property of the Company Partnership is subsequently adjusted, subsequent allocations of income, gain, loss and deduction with respect to any such property shall take into account any variation between the adjusted basis of such asset for federal income tax purposes and its respective Book Value in the manner provided under Section 704(c) of the Code and the Treasury Regulations thereunder. (d) Allocations pursuant to this Section 6.7 4.7 are solely for federal, state, and local income tax purposes, and shall not affect, or in any way be taken into account in computing, any Member’s Partner's Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement. Any election or other decisions relating to such allocations (including any elections under Treasury Regulation Section 1.704-3) shall be made by the General Partner in its sole discretion.

TAX ALLOCATIONS AND BOOK ALLOCATIONS. (a) Except as otherwise provided in this Section 6.7section 5.8, for federal income tax purposes, each item of income, gain, loss and deduction shall, to the extent appropriate, be allocated among the Members in the same manner as its correlative item of “"book” " income, gain, loss or deduction has been allocated pursuant to the other provisions of this Article VI.V. (b) SECTION 5.8.1. In accordance with Code IRC Section 704(c) and the Treasury Regulations thereunder, depreciation, amortization, gain and loss, as determined for tax purposes, with respect to any property whose Book Value differs from its adjusted basis for federal income tax purposes shall, for tax purposes, be allocated among the Members so as to take account of any variation between the adjusted basis of such property to the Company for federal income tax purposes and its Book Value, such allocation to be made by the Approval of the Managers in any manner which is permissible under said Code IRC Section 704(c) and the Treasury Regulations thereunder and the Treasury Regulations under Code IRC Section 704(b). (c) SECTION 5.8.2. In the event the Book Value of any property of the Company is subsequently adjusted, subsequent allocations of income, gain, loss and deduction with respect to any such property shall take into account any variation between the adjusted basis of such asset assets for federal income tax purposes and its respective Book Value in the manner provided under Section 704(c) of the Code IRC and the Treasury Regulations thereunder. (d) SECTION 5.8.3. Allocations pursuant to this Section 6.7 section 5.8 are solely for purposes of federal, state, state and local income tax purposes, taxes and shall not affect, or in any way be taken into account in computing, any Member’s 's Capital Account or share of Net Profits, Net Losses, other items, or distributions pursuant to any provision of this Agreement.