Epstein Secrets

Account the items described in Regulations Sections 1.704-1(bX2XiiXdX4), 1.704-1(bX2XiiXdX5) and 1.704-1(bX2Xii)(dX6). The foregoing definition of Adjusted Capital Account Deficit is intended to comply with the provisions of Regulations Section 1.704-1(bX2XiiXd) and shall be interpreted consistently therewith.

e economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704- 2(i)(1). 4.2.6 Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Sections 734(b)

nt the items described in Regulations Sections 1.704-1(bX2)(iiXdX4), 1.704-1(b)(2Xii)(d)(5) and 1.704-1(b)(2)(ii)(dX6). The foregoing definition of Adjusted Capital Account Deficit is intended to comply with the provisions of Regulations Section 1.704-1(bX2Xii)(d) and shall be interpreted consistently therewith

e economic risk of loss with respect to the Member Nonrecourse Debt to which such Member Nonrecourse Deductions are attributable in accordance with Treasury Regulations Section 1.704- 2(i)(1). 4.2.6 Section 754 Adjustment. To the extent an adjustment to the adjusted tax basis of any Company asset pursuant to Code Sections 734(b)

ebit such Capital Account by the items described in Treasury Regulations Sections 1.704-1(b)(2)(ii)(d)(4), (5) and (6). The foregoing definition of Adjusted Capital Account Deficit is intended to comply with the provisions of Treasury Regulations Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistently

ermined pursuant to Treasury Regulations Sections 1.704- 2(g) and 1.704-2(i)(5). The items to be so allocated shall be determined in accordance with Treasury Regulations Section 1.704- 2(0. This Section 5.2.1 is intended to comply with the minimum gain chargeback requirement in such Treasury Regulations Section and shall be interpr