Epstein Secrets

31 ARTICLE XII ACCOUNTING AND REPORTS 31 Section 12.01 Books 32 Section 12.02 Tax Matters Partner 32 Section 12.03 Reports. 32 Section 12.04 Partner Tax Basis 33 ARTICLE XIII AMENDMENTS 33 Section 13.01 Amendments 33 ARTICLE XIV MISCELLANEOUS 33 Section 14.01 General 34 Section 14.02 Notices 34

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

31 ARTICLE XII ACCOUNTING AND REPORTS 31 Section 12.01 Books 32 Section 12.02 Tax Matters Partner 32 Section 12.03 Reports. 32 Section 12.04 Partner Tax Basis 33 ARTICLE XIII AMENDMENTS 33 Section 13.01 Amendments 33 ARTICLE XIV MISCELLANEOUS 33 Section 14.01 General 34 Section 14.02 Notices 34

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

31 ARTICLE XII ACCOUNTING AND REPORTS 31 Section 12.01 Books 32 Section 12.02 Tax Matters Partner 32 Section 12.03 Reports. 32 Section 12.04 Partner Tax Basis 33 ARTICLE XIII AMENDMENTS 33 Section 13.01 Amendments 33 ARTICLE XIV MISCELLANEOUS 33 Section 14.01 General 34 Section 14.02 Notices 34

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)