Examples of Initial Contributed Property in a sentence
By executing this Agreement, each Partner hereby agrees to report income, gain, loss and deduction on such Partner's federal income tax return in a manner that is consistent with the use of the traditional method of allocation with respect to the Initial Contributed Property.
The Partnership may elect the traditional method of allocation contained in Section 1.704- 3(b) of the Regulations to take into account any variation between the adjusted basis and the fair market value of the Initial Contributed Property at the time of the contribution ("Precontribution Gain") on a Property-by-Property basis.
By executing this Agreement, each Partner hereby agrees to report income, gain, loss and deduction on such Partner’s federal income tax return in a manner that is consistent with the use of the traditional method of allocation with respect to the Initial Contributed Property.
The Partnership may elect the traditional method of allocation contained in Section 1.704- 3(b) of the Regulations to take into account any variation between the adjusted basis and the fair market value of the Initial Contributed Property at the time of the contribution (“Precontribution Gain”) on a Property-by-Property basis.
Within ninety (90) calendar days after the filing of the U.S. federal income Tax Return of Parent for each Taxable Year in which the ICP 704(c) Application continues to be effective with respect to the Initial Contributed Property, Parent shall deliver to PDC a detailed schedule (the “ICP 704(c) Schedule”) setting forth the application of Section 704(c) to the Initial Contributed Property and the Members for such Taxable Year as well as all prior Taxable Years.
If there is a default under Section 4.2(d) and such default has not been cured on or before the date that is ten (10) days after CNL LP receives written notice of such default (the “Priority Loan Date”), then GW LP shall be deemed to have made a loan to the Partnership in an amount equal to the difference between seventy percent (70%) and the Percentage Interest of the CNL Partners on the Priority Loan Date multiplied by the Initial Contributed Property Value (the “Deemed Priority Loan”).
The Partners further agree that because the Partnership was a “disregarded entity” for federal income tax purposes prior to the Effective Date, for federal income tax purposes (i) the CNL Partners will be deemed to have purchased a portion of the Initial Contributed Property from Great Wolf Resorts (which indirectly owns 100% of GW LP and Wolf Sandusky), and (ii) Great Wolf Resorts and the CNL Partners will be deemed to have jointly contributed the Initial Contributed Property to the Partnership.
The Partnership shall use the traditional method of allocation contained in Section 1.704-3(b) of the Regulations to take into account any variation between the adjusted basis and the fair market value of the Initial Contributed Property at the time of the contribution ("Precontribution Gain ").