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ll give to each Partner, written notice (the "Offer Notice") which shall include the following: (I) the identity of the Purchaser; (2) a copy of the Purchase Offer; (3) a statement signed by the Purchaser to the effect that, upon purchase of the Offered Interests, the Purchaser agrees to become a Partner
twithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and 704(c) of the Code and the Treasury Regulations promulgated thereunder, income, gain, loss and deduction with respect to property contributed to the Partnership by a Partner shall be allocated am
ll give to each Partner, written notice (the "Offer Notice") which shall include the following: (I) the identity of the Purchaser; (2) a copy of the Purchase Offer; (3) a statement signed by the Purchaser to the effect that, upon purchase of the Offered Interests, the Purchaser agrees to become a Partner
twithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and 704(c) of the Code and the Treasury Regulations promulgated thereunder, income, gain, loss and deduction with respect to property contributed to the Partnership by a Partner shall be allocated am
ll give to each Partner, written notice (the "Offer Notice") which shall include the following: (I) the identity of the Purchaser; (2) a copy of the Purchase Offer; (3) a statement signed by the Purchaser to the effect that, upon purchase of the Offered Interests, the Purchaser agrees to become a Partner
twithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and 704(c) of the Code and the Treasury Regulations promulgated thereunder, income, gain, loss and deduction with respect to property contributed to the Partnership by a Partner shall be allocated am
all give to each Member, written notice (the "Offer Notice") which shall include the following: (1) the identity of the Purchaser; (2) a copy of the Purchase Offer; (3) a statement signed by the Purchaser to the effect that, upon purchase of the Offered Interests, the Purchaser agrees to become a Member,
twithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and 704(c) of the Code and the Treasury Regulations promulgated thereunder, income, gain, loss and deduction with respect to property contributed to the Company by a Member shall be allocated among t
Entities connected to both Purchase and the Treasury Regulations

New York
LOCATIONLeon Black
PERSON
United States
LOCATIONthe Person or Persons
ORGANIZATIONReliance
ORGANIZATIONOccasioning Dissolution
LOCATIONthe Offered Interests
ORGANIZATIONUniform Transfers to Minors Act
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONNet Profit
ORGANIZATION
Ghislaine Maxwell
PERSONNet Profit and Net Loss
ORGANIZATIONCertificate of Formation
ORGANIZATION
Samantha Power
PERSONAllocation of Profits
ORGANIZATIONthe United States Treasury
LOCATIONFederal, State
ORGANIZATIONthe Offer Price
ORGANIZATIONAccounting Period
ORGANIZATIONElysium Management LLC
ORGANIZATION