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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
hdraw from the Partnership pursuant to Section 6.5.1 (the "Withdrawing Partner"), the Class B General Partners may, but are not required to, redeem the Withdrawing Partner's Partnership Interest, in whole or in part, by distributing assets to such Withdrawing Partner, the fair market value of which is to be determined by the Class B General
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
hdraw from the Partnership pursuant to Section 6.5.1 (the "Withdrawing Partner"), the Class B General Partners may, but are not required to, redeem the Withdrawing Partner's Partnership Interest, in whole or in part, by distributing assets to such Withdrawing Partner, the fair market value of which is to be determined by the Class B General
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
hdraw from the Partnership pursuant to Section 6.5.1 (the "Withdrawing Partner"), the Class B General Partners may, but are not required to, redeem the Withdrawing Partner's Partnership Interest, in whole or in part, by distributing assets to such Withdrawing Partner, the fair market value of which is to be determined by the Class B General
Entities connected to both the Treasury Regulations and the Withdrawing Partner's Partnership Interest
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
ORGANIZATION
Wilmington
LOCATIONthe Offered Interests
ORGANIZATIONthe United States Treasury
LOCATIONNet Profit and Net Loss
ORGANIZATIONCertificate of Formation
ORGANIZATIONWithdrawing Partner
PERSONElysium Management LLC
ORGANIZATIONCorporation Services Company
ORGANIZATION