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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
sustain. ARTICLE IV ALLOCATION OF PROFIT AND LOSS 4.1 Allocation of Profits and Losses. 4.1.1 The Partnership's Net Profit and Net Loss for any Accounting Period shall be allocated among the Partners in proportion to their Percentage Interests. 4.1.2 The Partnership's items of income, gain, loss and deductio
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
sustain. ARTICLE IV ALLOCATION OF PROFIT AND LOSS 4.1 Allocation of Profits and Losses. 4.1.1 The Partnership's Net Profit and Net Loss for any Accounting Period shall be allocated among the Partners in proportion to their Percentage Interests. 4.1.2 The Partnership's items of income, gain, loss and deductio
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
sustain. ARTICLE IV ALLOCATION OF PROFIT AND LOSS 4.1 Allocation of Profits and Losses. 4.1.1 The Partnership's Net Profit and Net Loss for any Accounting Period shall be allocated among the Partners in proportion to their Percentage Interests. 4.1.2 The Partnership's items of income, gain, loss and deductio
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
may sustain. ARTICLE IV ALLOCATION OF PROFIT AND LOSS 4.1 Allocation of Profits and Losses. 4.1.1 The Company's Net Profit and Net Loss for any Accounting Period shall be allocated among the Members in proportion to their Percentage Interests. 4.1.2 The Company's items of income, gain, loss and deduction sha
Entities connected to both the Treasury Regulations and Accounting Period
Reliance
ORGANIZATIONthe Person or Persons
ORGANIZATIONthe Offered Interests
ORGANIZATION
United States
LOCATIONAllocation of Profits and Losses
ORGANIZATION
the Cayman Islands
LOCATIONUniform Transfers to Minors Act
ORGANIZATIONLeon Black
PERSONthe United States Treasury
LOCATIONFederal, State
ORGANIZATIONCertificate of Formation
ORGANIZATIONthe Offer Price
ORGANIZATIONAllocation of Profits
ORGANIZATIONNet Profit
ORGANIZATIONOccasioning Dissolution
LOCATIONPurchase
LOCATIONNet Profit and Net Loss
ORGANIZATIONthe Delaware
ORGANIZATION
Wilmington
LOCATIONthe Master Fund
ORGANIZATION