Common use of Tax Termination Clause in Contracts

Tax Termination. In addition to termination of the Company following --------------- its Dissolution, a termination of the Company will occur, for federal income tax purposes only, on the date the Company is terminated under (S) 708(b)(1) of the Code. Under current law, events causing such a termination include the sale or exchange of 50% or more of the total interest in the capital and profits of the Company within a 12-month period. Upon the occurrence of a termination under (S) 708(b)(1) of the Code, a constructive Liquidation and a constructive reformation of the Company as a tax partnership will be deemed to occur for federal income tax purposes. All adjustments and computations will be made under this Agreement as if the constructive transactions had actually occurred, and the Capital Accounts of the Members in such new tax partnership will be determined and maintained in accordance with the (S) 704(b) Regulations.

Tax Termination. In addition to termination of the Company following --------------- its Dissolution, a termination of the Company will occur, for federal income tax purposes only, on the date the Company is terminated under (S) Section 708(b)(1) of the Code. Under current law, events causing such a termination include the sale or exchange of 50% or more of the total interest in the capital and profits of the Company within a 12-month period. Upon the occurrence of a termination under (S) Section 708(b)(1) of the Code, a constructive Liquidation and a constructive reformation of the Company as a tax partnership will be deemed to occur for federal income tax purposes. All adjustments and computations will be made under this Agreement as if the constructive transactions had actually occurred, and the Capital Accounts of the Members in such new tax partnership will be determined and maintained in accordance with the (S) Section 704(b) Regulations.

Tax Termination. In addition to termination of the Company following --------------- its Dissolution, a termination of the Company will occur, occur for federal income tax purposes only, on the date the Company is terminated under (S) 708(b)(1ss.708(b)(1) of the Code. Under current law, events causing such a termination include the sale or exchange of fifty percent (50% %) or more of the total interest in the capital and profits of the Company within a 12-month period. Upon the occurrence of a termination under (S) 708(b)(1ss.708(b)(1) of the Code, a constructive Liquidation liquidation and a constructive reformation of the Company as a tax partnership will be deemed to occur for federal income tax purposes. All adjustments and computations will be made under this Agreement as if the constructive transactions had actually occurred, and the Capital Accounts of the Members in such new tax partnership will be determined and maintained in accordance with the (S) 704(bss.704(b) Regulations.

Tax Termination. In addition to termination of the Company following --------------- its Dissolution, a termination of the Company will occur, occur for federal income tax purposes only, on the date the Company is terminated under (S) Section 708(b)(1) of the Code. Under current law, events causing such a termination include the sale or exchange of fifty percent (50% %) or more of the total interest in the capital and profits of the Company within a 12-month period. Upon the occurrence of a termination under (S) Section 708(b)(1) of the Code, a constructive Liquidation liquidation and a constructive reformation of the Company as a tax partnership will be deemed to occur for federal income tax purposes. All adjustments and computations will be made under this Agreement as if the constructive transactions had actually occurred, and the Capital Accounts of the Members in such new tax partnership will be determined and maintained in accordance with the (S) Section 704(b) Regulations.