Epstein Secrets

f Company income and gain (including gross income) shall be specially allocated to such Member to the extent required and in the manner specified by Treasury Regulations Sections 1.704-1(b)(2)(ii)(d) in an amount and manner sufficient to eliminate the such deficit balance as quickly as possible. This provision is intended to

mbers in a manner designed to result in each Member having a Capital Account balance equal to what it would have been had the original allocation of Net Profits or Net Losses pursuant to Sections 5.2 through 5.5 above not occurred. The Manager will apply this Section 5.6 at such times, and in such manner, and will make a

n during a Company Fiscal Year, the Members shall be B - 4 404348-3-W EFTA00284035 allocated items of Company income and gain in accordance with Treasury Regulations Sections 1.704- 2(f) and 1.704-2(i)(4). (d) Qualified Income Offset. In addition, in the event that any Member has a deficit Capital Account at the end of

ts Capital Account. B-3 General Allocations. (a) Hypothetical Liquidation. The items of income, gain, loss and expense of the Company comprising Net Profits or Net Losses for a Fiscal Year shall be allocated among the Persons who were Members during such Fiscal Year in a manner that will, as nearly as possible, cause

n during a Company Fiscal Year, the Members shall be B - 4 404348-3-W EFTA00284052 allocated items of Company income and gain in accordance with Treasury Regulations Sections 1.704- 2(f) and 1.704-2(i)(4). (d) Qualified Income Offset. In addition, in the event that any Member has a deficit Capital Account at the end of

ts Capital Account. B-3 General Allocations. (a) Hypothetical Liquidation. The items of income, gain, loss and expense of the Company comprising Net Profits or Net Losses for a Fiscal Year shall be allocated among the Persons who were Members during such Fiscal Year in a manner that will, as nearly as possible, cause