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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
ows: 1.1 ARTICLE I ESTABLISHMENT OF THE PARTNERSHIP Formation. The Partnership was formed as a limited partnership pursuant to the provisions of the Revised Limited Partnership Act as adopted in the State of Delaware (the "Act"). This Agreement sets forth fully the agreements and understandings of the Partners in respect of th
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
ows: 1.1 ARTICLE I ESTABLISHMENT OF THE PARTNERSHIP Formation. The Partnership was formed as a limited partnership pursuant to the provisions of the Revised Limited Partnership Act as adopted in the State of Delaware (the "Act"). This Agreement sets forth fully the agreements and understandings of the Partners in respect of th
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
ows: 1.1 ARTICLE I ESTABLISHMENT OF THE PARTNERSHIP Formation. The Partnership was formed as a limited partnership pursuant to the provisions of the Revised Limited Partnership Act as adopted in the State of Delaware (the "Act"). This Agreement sets forth fully the agreements and understandings of the Partners in respect of th
Entities connected to both the Treasury Regulations and the Revised Limited Partnership Act
the Person or Persons
ORGANIZATIONReliance
ORGANIZATIONFederal, State
ORGANIZATIONLeon Black
PERSONOccasioning Dissolution
LOCATIONthe Offer Price
ORGANIZATIONUniform Transfers to Minors Act
ORGANIZATIONAccounting Period
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONAllocation of Profits
ORGANIZATIONPurchase
LOCATIONNet Profit
ORGANIZATIONthe Offered Interests
ORGANIZATION
Wilmington
LOCATIONthe United States Treasury
LOCATIONNet Profit and Net Loss
ORGANIZATIONCertificate of Formation
ORGANIZATIONWithdrawing Partner
PERSONElysium Management LLC
ORGANIZATIONCorporation Services Company
ORGANIZATION