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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
artners; (iv) The transferee has paid or agreed to pay all reasonable expenses relating to such admission; and (v) In the event of a transfer of Class A General Partnership Interests or Class B General Partnership Interests, a majority in interest of the Partners have provided written consent to the admission of such transferee
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
d Partner's then existing Partnership Interests, as the case may be, in4he-sele-chseretien-ef-sush-Glass-A-Genecal- • ' Partners-being converted to Class A General Partnership Interests in the sole discretion of the then serving Class A General Partners. As conditions precedent to a designated Class B General Partner or a designate
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
artners; (iv) The transferee has paid or agreed to pay all reasonable expenses relating to such admission; and (v) In the event of a transfer of Class A General Partnership Interests or Class B General Partnership Interests, a majority in interest of the Partners have provided written consent to the admission of such transferee
Entities connected to both the Treasury Regulations and Class A General Partnership Interests
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