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l be adjusted by the amount of Depreciation rather than the amount of depredation determined for U.S. federal income tax purposes. "Closing" means the Initial Closing or a Subsequent Closing, as the case may be. "Code" means the U.S. Internal Revenue Code of 1986, as amended from time to time, or any successor st
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
l be adjusted by the amount of Depreciation rather than the amount of depredation determined for U.S. federal income tax purposes. "Closing" means the Initial Closing or a Subsequent Closing, as the case may be. "Code" means the U.S. Internal Revenue Code of 1986, as amended from time to time, or any successor st
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
be adjusted by the amount of Depreciation rather than the amount of depreciation determined for U.S. federal income tax purposes. "Closing" means the Initial Closing or a Subsequent Closing, as the case may be. "Code" means the U.S. Internal Revenue Code of 1986, as amended from time to time, or any successor st
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 the Initial Closing and the Partnership Minimum Gain
the U.S. Investment Company Act
ORGANIZATION
United States
LOCATIONthe New York Stock Exchange
ORGANIZATION
FedEx
ORGANIZATION
Dover
LOCATION
the Cayman Islands
LOCATIONLimited Partner Interests
ORGANIZATION
New York
LOCATIONthe Southern District
LOCATION
United States District Court
ORGANIZATIONHoneycomb Asset Management LP
ORGANIZATIONClasses of Interests
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