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state or local taxing authority of such amounts as may be necessary to discharge such Partner's income tax liability (including but not limited to Federal, State, local or otherwise) and (ii) if such Partner is under the age of majority, to a custodian on behalf of such Partner. 5.2 Distributions Upon Windi
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
state or local taxing authority of such amounts as may be necessary to discharge such Partner's income tax liability (including but not limited to Federal, State, local or otherwise) and (ii) if such Partner is under the age of majority, to a custodian on behalf of such Partner. 5.2 Distributions Upon Windi
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
state or local taxing authority of such amounts as may be necessary to discharge such Partner's income tax liability (including but not limited to Federal, State, local or otherwise) and (ii) if such Partner is under the age of majority, to a custodian on behalf of such Partner. 5.2 Distributions Upon Windi
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
y state or local taxing authority of such amounts as may be necessary to discharge such Member's income tax liability (including but not limited to Federal, State, local or otherwise) and (ii) if such Member is under the age of majority, to a custodian on behalf of such Member. 5.2 Distributions Upon Winding
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 Federal, State and the Treasury Regulations

United States
LOCATION
Samantha Power
PERSONLeon Black
PERSON
New York
LOCATIONthe Person or Persons
ORGANIZATIONReliance
ORGANIZATIONthe Offered Interests
ORGANIZATIONPurchase
LOCATIONUniform Transfers to Minors Act
ORGANIZATIONCertificate of Formation
ORGANIZATIONthe United States Treasury
LOCATIONAccounting Period
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONAllocation of Profits
ORGANIZATIONthe Offer Price
ORGANIZATIONNet Profit
ORGANIZATIONOccasioning Dissolution
LOCATIONNet Profit and Net Loss
ORGANIZATION
Wilmington
LOCATIONthe Southern District
LOCATION