Common use of Tax Partnerships Clause in Contracts

Tax Partnerships. None of the Properties is subject to a tax partnership, including, without limitation, none of such Properties are subject to any operating agreement or other arrangement under which the parties thereto have not made an effective election pursuant to Section 761 of the Internal Revenue Code of 1986 (herein called the “Internal Revenue Code”), and the Treasury Regulations promulgated thereunder, to be excluded from the application of Subchapter K, Chapter 1, Subtitle A, of the Internal Revenue Code.

Appears in 4 contracts

Samples: Purchase and Sale Agreement, Purchase and Sale Agreement (Apollo Resources International Inc), Purchase and Sale Agreement (Whittier Energy Corp)

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Tax Partnerships. None of the Properties is are subject to a tax partnership, including, without limitation, none any of such the Properties that are subject to any operating agreement or other arrangement under which the parties thereto have not made an effective election pursuant to Section 761 of the Internal Revenue Code of 1986 (herein called the “Internal Revenue Code”), "INTERNAL REVENUE CODE") and the Treasury Regulations promulgated thereunder, to be excluded from the application of Subchapter K, Chapter 1, Subtitle A, of the Internal Revenue Code.

Appears in 1 contract

Samples: Contribution Agreement (Primeenergy Corp)

Tax Partnerships. None of the Properties Assets is subject to a tax partnership, including, without limitation, none of such Properties properties are subject to any operating agreement or other arrangement under which the parties thereto have not made an effective election pursuant to Section 761 of the Internal Revenue Code of 1986 (herein called the “Internal Revenue Code”), and the Treasury Regulations promulgated thereunder, to be excluded from the application of Subchapter K, Chapter 1, Subtitle A, of the Internal Revenue Code.

Appears in 1 contract

Samples: Purchase and Sale Agreement (BreitBurn Energy Partners L.P.)

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Tax Partnerships. None of the Properties is subject to a tax partnership, including, without limitation, none of such Properties properties are subject to any operating agreement or other arrangement under which the parties thereto have not made an effective election pursuant to Section 761 of the Internal Revenue Code of 1986 (herein called the “Internal Revenue Code”"INTERNAL REVENUE CODE"), and the Treasury Regulations promulgated thereunder, to be excluded from the application of Subchapter K, Chapter 1, Subtitle A, of the Internal Revenue Code.

Appears in 1 contract

Samples: Purchase and Sale Agreement (Benz Energy LTD /Can/)

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