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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
ittee or other similar fiduciary, or (ii) a licensed physician or psychiatrist appointed either by a majority of the other General Partners of that Class of Partnership Interests or by a majority in interest of the Partners (excluding any Partnership Interests held by the General Partner whose capacity is at issue) certify in
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
ittee or other similar fiduciary, or (ii) a licensed physician or psychiatrist appointed either by a majority of the other General Partners of that Class of Partnership Interests or by a majority in interest of the Partners (excluding any Partnership Interests held by the General Partner whose capacity is at issue) certify in
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
ittee or other similar fiduciary, or (ii) a licensed physician or psychiatrist appointed either by a majority of the other General Partners of that Class of Partnership Interests or by a majority in interest of the Partners (excluding any Partnership Interests held by the General Partner whose capacity is at issue) certify in
Entities connected to both the Treasury Regulations and Class of 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