Tax Treatment; Purchase Price Allocation. (a) Buyer and Seller acknowledge that the transactions under this Agreement will be treated for federal income Tax purposes as a purchase and sale of the assets of the Company and that such purchase and sale constitutes an applicable asset acquisition pursuant to Section 1060 of the Code.
Appears in 2 contracts
Samples: Purchase and Sale Agreement, Purchase and Sale Agreement (Atlas Pipeline Partners Lp)
Tax Treatment; Purchase Price Allocation. (a) Buyer and Seller acknowledge The parties agree that the transactions under this Agreement will be treated for federal income Tax purposes as a purchase and sale of the Shares shall be treated for U.S. federal income tax purposes as an acquisition by Purchaser of all of the assets of the Transferred Company and that such the purchase and sale constitutes of Shares will be treated as an “applicable asset acquisition pursuant to acquisition” within the meaning of Section 1060 of the CodeCode with respect to Purchaser (the “Transaction Tax Treatment”).
Appears in 2 contracts
Samples: Purchase and Sale Agreement, Purchase and Sale Agreement (Cit Group Inc)
