Tax Partnerships. Except as provided in Schedule 10.1.21 none of the Properties are subject to tax partnership reporting requirements under applicable provisions of the Code. For any Property that is the subject of tax partnership reporting requirements, Seller will use its commercially reasonable efforts to effect a §754 election with respect any such tax partnerships.
Appears in 3 contracts
Samples: Purchase and Sale Agreement, Purchase and Sale Agreement (Apache Corp), Purchase and Sale Agreement (Apache Corp)
Tax Partnerships. Except as provided in Schedule 10.1.21 Exhibit 3.12, none of the Properties Assets are subject to tax partnership reporting requirements under applicable provisions of the Internal Revenue Code of 1986, as amended (the “Code”). For any Property Asset that is the subject of tax partnership reporting requirements, Seller will use its commercially reasonable efforts to effect a §754 election with respect any such tax partnerships.
Appears in 1 contract
Samples: Purchase and Sale Agreement (Rosetta Resources Inc.)