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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
BUTIONS AND CAPITAL ACCOUNTS 3.1 Capital Accounts. 3.1.1 A separate capital account (a "Capital Account") shall be maintained for each Partner. Each Partner's Capital Account shall be credited with (i) the amount of such Partner's aggregate capital contributions made in cash and the fair market value of al
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
BUTIONS AND CAPITAL ACCOUNTS 3.1 Capital Accounts. 3.1.1 A separate capital account (a "Capital Account") shall be maintained for each Partner. Each Partner's Capital Account shall be credited with (i) the amount of such Partner's aggregate capital contributions made in cash and the fair market value of al
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
BUTIONS AND CAPITAL ACCOUNTS 3.1 Capital Accounts. 3.1.1 A separate capital account (a "Capital Account") shall be maintained for each Partner. Each Partner's Capital Account shall be credited with (i) the amount of such Partner's aggregate capital contributions made in cash and the fair market value of al
Entities connected to both the Treasury Regulations and Each Partner's
the Person or Persons
ORGANIZATIONReliance
ORGANIZATIONNet Profit
ORGANIZATIONNet Profit and Net Loss
ORGANIZATIONLeon Black
PERSONUniform Transfers to Minors Act
ORGANIZATIONAccounting Period
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONAllocation of Profits
ORGANIZATIONPurchase
LOCATIONthe Offered Interests
ORGANIZATIONCertificate of Formation
ORGANIZATION
Wilmington
LOCATIONthe United States Treasury
LOCATIONFederal, State
ORGANIZATIONOccasioning Dissolution
LOCATIONthe Offer Price
ORGANIZATIONWithdrawing Partner
PERSONElysium Management LLC
ORGANIZATIONCorporation Services Company
ORGANIZATION