to eliminate Book-Tax Disparities. In an attempt to eliminate Book-Tax Disparities attributable to a Contributed Property or Adjusted Property, items of income, gain, loss, and deduction shall be allocated for United States federal income tax purposes among the Members according to the traditional method under Regulations Section 1.704-3(b).
Appears in 1 contract
Samples: Equity Purchase Agreement (Morgans Hotel Group Co.)
to eliminate Book-Tax Disparities. In an attempt to eliminate Book-Tax Disparities attributable to a Contributed Property or Adjusted Property, items of income, gain, loss, and deduction shall be allocated for United States federal income tax purposes among the Members according to using the traditional remedial method under Regulations described in Regulation Section 1.704-3(b3(d).
Appears in 1 contract
Samples: Limited Liability Company Agreement (Tarragon Realty Investors Inc)
to eliminate Book-Tax Disparities. In an attempt to eliminate Book-Tax Disparities attributable to a Contributed Property or Adjusted Property, items of income, gain, loss, and deduction shall be allocated for United States federal income tax purposes among the Members according to using the traditional remedial method under described in Regulations Section 1.704-3(b3(d).
Appears in 1 contract
to eliminate Book-Tax Disparities. In an attempt to eliminate Book-Tax Disparities attributable to a Contributed Property or Adjusted Property, items of income, gain, loss, and deduction shall be allocated for United States federal income tax purposes among the Members as follows according to the traditional method under Regulations Section 1.704-3(b).
Appears in 1 contract
Samples: Master Purchase Agreement (Morgans Hotel Group Co.)
