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rest of any Partner pursuant to the express provisions of this Agreement; (i) to execute and deliver all documents in connection with the sale of Limited Partner Interests, including, but not limited to, the Subscription Agreements; (j) to sell, exchange, transfer or otherwise dispose of all or any portion of the Inv
respect to each partner nonrecourse debt (as defined in Treasury DOC ID • 26354060.5 15 EFTA00803533 Regulations Section I .704-2(bX4)) equal to the Partnership Minimum Gain that would result if such partner nonrecourse debt were treated as a nonrecourse liability (as defined in Treasury Regulations Section I .752-I(aX2
rest of any Partner pursuant to the express provisions of this Agreement; (i) to execute and deliver all documents in connection with the sale of Limited Partner Interests, including, but not limited to, the Subscription Agreements; (j) to sell, exchange, transfer or otherwise dispose of all or any portion of the Inv
respect to each partner nonrecourse debt (as defined in Treasury DOC ID • 26354060.5 15 EFTA00614677 Regulations Section I .704-2(bX4)) equal to the Partnership Minimum Gain that would result if such partner nonrecourse debt were treated as a nonrecourse liability (as defined in Treasury Regulations Section I .752-I(aX2
rest of any Partner pursuant to the express provisions of this Agreement; (i) to execute and deliver all documents in connection with the sale of Limited Partner Interests, including, but not limited to, the Subscription Agreements; (j) to sell, exchange, transfer or otherwise dispose of all or any portion of the Inv
respect to each partner nonrecourse debt (as defined in Treasury DOC ID • 26354060.5 15 EFTA00614635 Regulations Section I .704-2(bX4)) equal to the Partnership Minimum Gain that would result if such partner nonrecourse debt were treated as a nonrecourse liability (as defined in Treasury Regulations Section 1.752-1(aX2)
Entities connected to both Limited Partner Interests and the Partnership Minimum Gain
Classes of Interests: Side Letters
ORGANIZATION
Samantha Power
PERSONthe New York Stock Exchange
ORGANIZATION
FedEx
ORGANIZATION
Dover
LOCATION
the Cayman Islands
LOCATION
New York
LOCATIONthe Southern District
LOCATION
United States District Court
ORGANIZATIONHoneycomb Asset Management LP
ORGANIZATIONClasses of Interests
ORGANIZATIONthe Initial Closing
ORGANIZATIONSection 7.01 Management
ORGANIZATIONSection 9.03 Information on Investment
ORGANIZATIONSection 9.06 Limited Partners'
ORGANIZATIONOutside Activities
ORGANIZATIONARTICLE XII ACCOUNTING
ORGANIZATIONSection 12.03 Reports
ORGANIZATIONPartner Tax Basis
ORGANIZATIONThis Limited Partnership Agreement
ORGANIZATION