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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
3 5.1 Distributions Other Than Upon Winding-Up 13 5.2 Distributions Upon Winding Up 13 ARTICLE VI TRANSFERS AND WITHDRAWALS 14 6.1 Right of First Refusal 14 6.2 Permitted Transfers 16 6.3 Certain Prohibited Transfers 17 6.4 Other Purported Transfers 17 6.5 No Right to Withdraw 18 ARTICLE
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
3 5.1 Distributions Other Than Upon Winding-Up 13 5.2 Distributions Upon Winding Up 13 ARTICLE VI TRANSFERS AND WITHDRAWALS 14 6.1 Right of First Refusal 14 6.2 Permitted Transfers 16 6.3 Certain Prohibited Transfers 17 6.4 Other Purported Transfers 17 6.5 No Right to Withdraw 18 ARTICLE
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
3 5.1 Distributions Other Than Upon Winding-Up 13 5.2 Distributions Upon Winding Up 13 ARTICLE VI TRANSFERS AND WITHDRAWALS 14 6.1 Right of First Refusal 14 6.2 Permitted Transfers 16 6.3 Certain Prohibited Transfers 17 6.4 Other Purported Transfers 17 6.5 No Right to Withdraw 18 ARTICLE
Entities connected to both the Treasury Regulations and First Refusal

United States
LOCATIONReliance
ORGANIZATIONthe Person or Persons
ORGANIZATION
Samantha Power
PERSON
Wilmington
LOCATIONthe Offer Price
ORGANIZATIONUniform Transfers to Minors Act
ORGANIZATIONCertificate of Formation
ORGANIZATIONAccounting Period
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONAllocation of Profits
ORGANIZATIONthe Offered Interests
ORGANIZATIONNet Profit
ORGANIZATIONNet Profit and Net Loss
ORGANIZATIONLeon Black
PERSONPurchase
LOCATIONthe United States Treasury
LOCATIONFederal, State
ORGANIZATIONOccasioning Dissolution
LOCATIONWithdrawing Partner
PERSON