Tax Effects. The Transfer of the interest shall not, to the ----------- reasonable satisfaction of the General Partner, cause the Partnership to (A) terminate within the meaning of Section 708 of the Code; (B) qualify as a "publicly traded partnership" within the meaning of Section 469(k), 512(c)(2) or 7704 of the Code; or (C) be classified for Federal income tax purposes as an association taxable as a corporation.
Appears in 1 contract
Samples: Partnership Agreement (Hollywood Park Fall Operating Co)
Tax Effects. The Transfer of the interest shall not, to the ----------- reasonable satisfaction of the General Partner, cause the Partnership to (A) terminate within the meaning of Section 708 of the Code; (B) qualify as a "publicly traded partnership" within the meaning of Section 469(k), 512(c)(2) or 7704 of the Code; or (C) be classified for Federal income tax purposes as an association taxable as a corporation.
Appears in 1 contract
Samples: Agreement of Limited Partnership (Hollywood Park Inc/New/)
Tax Effects. The Transfer of the interest shall not, to the ----------- reasonable satisfaction of the General Partner, cause the Partnership to (A) terminate within the meaning of Section 708 of the Code; (B) qualify as a "βpublicly traded partnership" β within the meaning of Section 469(k), 512(c)(2) or 7704 of the Code; or (C) be classified for Federal income tax purposes as an association taxable as a corporation.
Appears in 1 contract
Tax Effects. The Transfer of the interest shall not, to the ----------- reasonable satisfaction of the General Partner, cause the Partnership to (A) terminate within the meaning of Section 708 of the Code; (B) qualify as a "publicly traded partnership" within the meaning of Section 469(k), 512(c)(2) or 7704 of the Code; or (C) be classified for Federal income tax purposes as an association taxable as a corporation.
Appears in 1 contract
Samples: Partnership Agreement (Switzerland County Development Corp)