Common use of Transfers Treated as Sales Clause in Contracts

Transfers Treated as Sales. Each Seller agrees to treat each transfer for all purposes other than federal income tax purposes and financial accounting purposes as a sale on all relevant books, records, financial statements and other applicable documents; for federal income tax purposes and financial accounting purposes, the parties hereto intend the contribution of Receivables by the Sellers to the Purchaser to be characterized as a contribution of property to a partnership in exchange for an interest in the partnership in which no gain or loss shall be recognized pursuant to Section 721(a) of the Internal Revenue Code of 1986, as amended. In the event that, notwithstanding the intent of each Seller, any transfer and assignment contemplated hereby is not held to be a sale, each Seller hereby grants to the Purchaser a security interest in the Receivables and Other Conveyed Property described in each Supplement.

Transfers Treated as Sales. Each Seller agrees to treat each transfer for all purposes other than federal income tax purposes and (but including, without limitation, financial accounting purposes purposes) as a sale on all relevant books, records, financial statements and other applicable documents; for federal income tax purposes and financial accounting purposes, the parties hereto intend the contribution of Receivables by the Sellers to the Purchaser to be characterized as a contribution of property to a partnership in exchange for an interest in the partnership in which no gain or loss shall be recognized pursuant to Section 721(a) of the Internal Revenue Code of 1986, as amended. In the event that, notwithstanding the intent of each Seller, any the transfer and assignment contemplated hereby is not held to be a sale, each Seller hereby grants to the Purchaser a security interest in the Receivables and Other Conveyed Property described in each Supplement.

Transfers Treated as Sales. Each Seller agrees to treat -------------------------- each transfer for all purposes other than federal income tax purposes and (but including, without limitation, financial accounting purposes purposes) as a sale on all relevant books, records, financial statements and other applicable documents; for federal income tax purposes and financial accounting purposes, the parties hereto intend the contribution of Receivables by the Sellers to the Purchaser to be characterized as a contribution of property to a partnership in exchange for an interest in the partnership in which no gain or loss shall be recognized pursuant to Section 721(a) of the Internal Revenue Code of 1986, as amended. In the event that, notwithstanding the intent of each Seller, any the transfer and assignment contemplated hereby is not held to be a sale, each Seller hereby grants to the Purchaser a security interest in the Receivables and Other Conveyed Property described in each Supplement.

Transfers Treated as Sales. Each Seller agrees to -------------------------- treat each transfer for all purposes other than federal income tax purposes and (but including, without limitation, financial accounting purposes purposes) as a sale on all relevant books, records, financial statements and other applicable documents; for federal income tax purposes and financial accounting purposes, the parties hereto intend the contribution of Receivables by the Sellers to the Purchaser to be characterized as a contribution of property to a partnership in exchange for an interest in the partnership in which no gain or loss shall be recognized pursuant to Section 721(a) of the Internal Revenue Code of 1986, as amended. In the event that, notwithstanding the intent of each Seller, any the transfer and assignment contemplated hereby is not held to be a sale, each Seller hereby grants to the Purchaser a security interest in the Receivables and Other Conveyed Property described in each Supplement.