Common use of Tax Allocations Clause in Contracts

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders 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 initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders 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 initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Capital Account or share of ProfitsProfits , Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders so as to take account of any variation between the adjusted basis of such Property property to the Company for federal income tax purposes and its initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors Governors in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 5.10 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders 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 initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s 's Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders 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 initial Gross Asset Value (computed in accordance with using such allocation method as may be provided by Regulations and selected by the definition Board of Gross Asset Value)Directors. In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (iib) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Board of Directors in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 5.6 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s 's Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property property contributed to the capital of the Company Partnership shall, solely for tax purposes, be allocated among the Unit Holders Partners so as to take account of any variation between the adjusted basis of such Property property to the Company Partnership for federal income tax purposes and its initial Gross Asset Value (computed in accordance with the definition of Gross Asset ValueSection 1.08(r)(l). In the event the Gross Asset Value of any Company Partnership asset is adjusted pursuant to subparagraph (iiSection 1.08(r)(l) of the definition of Gross Asset Valuehereof, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors Managing General Partner in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 3.02(m) are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Person's Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders 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 initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset is determined or adjusted pursuant to subparagraph (i), (ii), or (iv) of the definition of Gross Asset ValueValue in Section 1.10(z) of this Agreement, subsequent allocations of income, gain, loss, loss and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors Board in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 are solely for purposes of federal, state, state and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Capital Account or share of Profits, Losses, other items, items or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section CODE SECTION 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders 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 initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s 's Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c)) . In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders 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 initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders 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 initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Class A Directors in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Treasury Regulations thereunder, income, gain, loss, loss and deduction with respect to any Property property contributed to the capital of the Company shall, solely for tax purposes, purposes be allocated among the Unit Holders Members so as to take account of any variation between the adjusted basis of such Property property to the Company for federal income tax purposes and its initial Gross Asset Value (computed as defined in accordance with the definition of Gross Asset ValueCode). In the event the Gross Asset Value of any Company asset Property is adjusted pursuant to subparagraph (ii) as permitted in accordance with the provisions of the definition of Gross Asset ValueTreasury Regulations Section 1.704-1(b)(2)(iv)(f), subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Treasury Regulations thereunder. Any All elections or other decisions relating to such allocations shall be made by the Directors Members, in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 “8.1” are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, computing any Unit HolderMember’s Capital Account or share of Net Profits, Net Losses, other items, items or distributions pursuant to any provision of this Agreement. Except as otherwise required in the Act, the Members shall not have any liability to restore all or any portion of a deficit balance in a Capital Account.

Tax Allocations. Code Section 704(c). 704(c).‌ In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders 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 initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Treasury Regulations thereunder, incomeIncome, gain, lossLoss, and deduction with respect to any Property property contributed to the capital of the Company Partnership shall, solely for tax purposes, be allocated among the Unit Holders Partners so as to take account of any variation between the adjusted basis of such Property property to the Company Partnership for federal income tax purposes and its initial Gross Asset Value (computed in accordance with the definition of Gross Asset Valuethis Agreement). In the event the Gross Asset Value of any Company Partnership asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Valuehereto, subsequent allocations of incomeIncome, gain, lossLoss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Treasury Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors General Partner with the Consent of the Special Limited Partner in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 10.6 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Person's Capital Account or share of ProfitsIncome, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) of the Code and the Treasury Regulations promulgated thereunder, income, gain, loss, and deduction with respect to any Property property contributed to the capital of the Company Partnership shall, solely for tax purposes, be allocated among the Unit Holders Partners so as to take account of any variation between the adjusted basis of such Property property to the Company Partnership for federal income tax purposes and its initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company Partnership asset is adjusted pursuant to subparagraph clause (iib) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the the- same manner as under Code Section 704(c) of the Code and the Treasury Regulations promulgated thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors Management Committee in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 6.05 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit HolderPartner’s Capital Account or share of ProfitsNet Income, LossesNet Loss, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section CODE SECTION 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders 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 initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Class A Directors in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s 's Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section ss. 704(c)) of the Code. In accordance with Code Section ss. 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders Members so as to take account of any variation between the adjusted basis of such Property property to the Company for federal income tax purposes and its initial Gross Asset Value (computed in accordance with the definition of Gross Asset ValueSection 1.27(a) hereof). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (iiSection 1.27(b) of the definition of Gross Asset Valuehereof, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section ss. 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors Managers in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 10.9 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Member's Capital Account or share of Net Profits, Net Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders 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 initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s 's Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.. 3.8

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders 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 initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Board of Directors in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 9.7 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Member's Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Treasury Regulations thereunder, income, gain, loss, and deduction with respect to any Property property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders Members so as to take account of any variation between the adjusted basis of such Property property to the Company for federal income tax purposes and its initial Gross Asset Value (computed in accordance with the definition of Gross Asset ValueSection 1(p)(i) hereof). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (iiSection 1(p)(ii) of the definition of Gross Asset Valuehereof, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Treasury Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors Board of Managers in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 7.5 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Person's Capital Account or share of Net Profits, Net Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property property contributed to the capital of the Company Partnership shall, solely for tax purposes, be allocated among the Unit Holders Partners so as to take account of any variation between the adjusted basis of such Property property to the Company Partnership for federal income tax purposes and its initial Gross Asset Value (computed in accordance with the definition of Gross Asset ValueSection 1.08(r)(I). In the event the Gross Asset Value of any Company Partnership asset is adjusted pursuant to subparagraph (iiSection 1.08(r)(I) of the definition of Gross Asset Valuehereof, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors Managing General Partner in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 3.02(m) are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Person's Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code CODE Section 704(c). In accordance with Code CODE Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders 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 initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code CODE Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property property contributed to the capital of the Company Partnership shall, solely for tax purposes, be allocated among the Unit Holders Partners so as to take account of any variation between the adjusted basis of such Property property to the Company Partnership for federal income tax lax purposes and its initial Gross Asset Value (computed in accordance with the definition of Gross Asset ValueSection 1.08(r)(l). In the event the Gross Asset Value of any Company Partnership asset is adjusted pursuant to subparagraph (iiSection 1.08(r)(1) of the definition of Gross Asset Valuehereof, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors Managing General Partner in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 3.02(m) are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Person's Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders 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 initial Gross Asset Value (computed in accordance with the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Board of Directors in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders Member so as to take account of any variation between the adjusted basis of such the Property to the Company for federal income tax purposes and its initial Gross Asset Value (computed in accordance with the definition Section 1.27(a) of Gross Asset Valueattached Exhibit 1). In the event If the Gross Asset Value of any Company asset is adjusted pursuant to subparagraph (iiSection 1.27(b) of the definition of Gross Asset Valueattached Exhibit 1, subsequent allocations of income, gain, loss, and deduction with respect to such the asset shall take account of any variation between the adjusted basis of such the asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such the allocations shall be made by the Directors Manager in any manner that reasonably reflects the purpose and intention of this the Agreement. Allocations pursuant to this Section 3.7 7.7 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Person's Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this the Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, and deduction with respect to any Property property contributed to the capital of the Company Partnership shall, solely for tax purposes, be allocated among the Unit Holders Partners so as to take account of any variation between the adjusted basis of such Property property to the Company Partnership for federal income tax purposes and its initial Gross Asset Value (computed in accordance with the definition of Gross Asset Valuevalue). In the event the Gross Asset Value of any Company Partnership asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c704 (c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors General Partner in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit HolderPartner’s Capital Account or share of Profits, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Treasury Regulations thereunder, income, gain, loss, and deduction with respect to any Property property contributed to the capital of the Company Partnership shall, solely for tax purposes, be allocated among the Unit Holders Partners so as to take account of any variation between the adjusted basis of such Property property to the Company Partnership for federal income tax purposes and its initial Gross Asset Value (computed in accordance with the definition of Gross Asset ValueSection 1.32(a) hereof). In the event the Gross Asset Value of any Company Partnership asset is adjusted pursuant to subparagraph (ii) of the definition of Gross Asset ValueSection 1.32 hereof, subsequent allocations of income, gain, loss, and deduction with respect to such asset shall take account of any variation between the adjusted basis of such asset for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Treasury Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors General Partner in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 10.6 are solely for purposes of federal, state, and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Person's Capital Account or share of ProfitsIncome, Losses, other items, or distributions pursuant to any provision of this Agreement.

Tax Allocations. Code Section 704(c). In accordance with Code Section 704(c) and the Regulations thereunder, income, gain, loss, loss and deduction with respect to any Property property contributed to the capital of the Company shall, solely for tax purposes, be allocated among the Unit Holders Members so as to take account of any variation between the adjusted basis of such Property property to the Company for federal income tax purposes and its initial Gross Asset Value (computed in accordance with clause (i) of the definition of Gross Asset Value). In the event the Gross Asset Value of any Company asset Property is adjusted pursuant to subparagraph clause (ii) of the definition of Gross Asset Value, subsequent allocations of income, gain, loss, loss and deduction with respect to such asset Property shall take account of any variation between the adjusted basis of such asset Property for federal income tax purposes and its Gross Asset Value in the same manner as under Code Section 704(c) and the Regulations thereunder. Any elections or other decisions relating to such allocations shall be made by the Directors Managers in any manner that reasonably reflects the purpose and intention of this Agreement. Allocations pursuant to this Section 3.7 5.1(f) are solely for purposes of federal, state, state and local taxes and shall not affect, or in any way be taken into account in computing, any Unit Holder’s Member's Capital Account or share of Profits, Losses, other items, items or distributions pursuant to any provision of this Agreement.