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3 5.1 Distributions Other Than Upon Winding-Up 13 5.2 Distributions Upon Winding Up 13 ARTICLE VI TRANSFERS AND WITHDRAWALS 14 6.1 Right of First Refusal 14 6.2 Permitted Transfers 16 6.3 Certain Prohibited Transfers 17 6.4 Other Purported Transfers 17 6.5 No Right to Withdraw 18 ARTICLE
ain, loss and deduction shall be allocated for Federal, state and local income tax purposes among the Partners proportionately to the allocation of Net Profit and Net Loss among the Partners. Notwithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and
3 5.1 Distributions Other Than Upon Winding-Up 13 5.2 Distributions Upon Winding Up 13 ARTICLE VI TRANSFERS AND WITHDRAWALS 14 6.1 Right of First Refusal 14 6.2 Permitted Transfers 16 6.3 Certain Prohibited Transfers 17 6.4 Other Purported Transfers 17 6.5 No Right to Withdraw 18 ARTICLE
ain, loss and deduction shall be allocated for Federal, state and local income tax purposes among the Partners proportionately to the allocation of Net Profit and Net Loss among the Partners. Notwithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and
3 5.1 Distributions Other Than Upon Winding-Up 13 5.2 Distributions Upon Winding Up 13 ARTICLE VI TRANSFERS AND WITHDRAWALS 14 6.1 Right of First Refusal 14 6.2 Permitted Transfers 16 6.3 Certain Prohibited Transfers 17 6.4 Other Purported Transfers 17 6.5 No Right to Withdraw 18 ARTICLE
ain, loss and deduction shall be allocated for Federal, state and local income tax purposes among the Partners proportionately to the allocation of Net Profit and Net Loss among the Partners. Notwithstanding the foregoing, solely for Federal, state and local income tax purposes, in accordance with Sections 704(b) and
Entities connected to both First Refusal and Net Profit and Net Loss
Reliance
ORGANIZATIONNet Profit
ORGANIZATIONLeon Black
PERSON
Wilmington
LOCATIONthe Treasury Regulations
ORGANIZATIONPurchase
LOCATIONthe United States Treasury
LOCATIONFederal, State
ORGANIZATIONthe Person or Persons
ORGANIZATIONAccounting Period
ORGANIZATIONAllocation of Profits and Losses
ORGANIZATIONAllocation of Profits
ORGANIZATIONEach Partner's
ORGANIZATIONCertificate of Formation
ORGANIZATIONUniform Transfers to Minors Act
ORGANIZATIONthe Offered Interests
ORGANIZATIONthe Offer Price
ORGANIZATIONOccasioning Dissolution
LOCATIONThe General Partnership Interests of a General Partner
ORGANIZATIONClass A General Partnership Interests
ORGANIZATION