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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
ners pursuant to this Agreement. 4.2.2 Notwithstanding any other provision of this Article IV, no Partner shall be allocated in any Fiscal Year of the Partnership any Net Loss to the extent such allocation would cause or increase a deficit balance in such Partner's Capital Account, determined after taking into account all
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
ners pursuant to this Agreement. 4.2.2 Notwithstanding any other provision of this Article IV, no Partner shall be allocated in any Fiscal Year of the Partnership any Net Loss to the extent such allocation would cause or increase a deficit balance in such Partner's Capital Account, determined after taking into account all
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
ners pursuant to this Agreement. 4.2.2 Notwithstanding any other provision of this Article IV, no Partner shall be allocated in any Fiscal Year of the Partnership any Net Loss to the extent such allocation would cause or increase a deficit balance in such Partner's Capital Account, determined after taking into account all
Entities connected to both the Treasury Regulations and the Partnership any Net Loss
the Person or Persons
ORGANIZATIONReliance
ORGANIZATIONFederal, State
ORGANIZATIONLeon Black
PERSONAccounting Period
ORGANIZATIONOccasioning Dissolution
LOCATIONthe Offer Price
ORGANIZATIONUniform Transfers to Minors Act
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