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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
ain, loss and deduction shall be allocated for Federal, state and local income tax purposes among the Partners proportionately to the allocation of Net Profit and Net Loss among the Partners. Notwithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and
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
ain, loss and deduction shall be allocated for Federal, state and local income tax purposes among the Partners proportionately to the allocation of Net Profit and Net Loss among the Partners. Notwithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and
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
ain, loss and deduction shall be allocated for Federal, state and local income tax purposes among the Partners proportionately to the allocation of Net Profit and Net Loss among the Partners. Notwithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and
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,
gain, loss and deduction shall be allocated for Federal, state and local income tax purposes among the Members proportionately to the allocation of Net Profit and Net Loss among the Members. Notwithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and 7
Entities connected to both Purchase and Net Profit and Net Loss
Leon Black
PERSONNet Profit
ORGANIZATIONCertificate of Formation
ORGANIZATIONReliance
ORGANIZATIONthe United States Treasury
LOCATIONFederal, State
ORGANIZATIONthe Person or Persons
ORGANIZATIONthe Treasury Regulations
ORGANIZATIONthe Offer Price
ORGANIZATIONAccounting Period
ORGANIZATIONthe Offered Interests
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONUniform Transfers to Minors Act
ORGANIZATIONAllocation of Profits
ORGANIZATIONOccasioning Dissolution
LOCATIONElysium Management LLC
ORGANIZATION
United States
LOCATION
Wilmington
LOCATIONEach Partner's
ORGANIZATIONWithdrawing Partner
PERSON